960067_NOV-2022-PC-0329 NOI_20220902

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR. NORTH CAROLINA
Director Environmental Quality
September 2, 2022
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
#7022 1670 0000 9974 5241
B & B Partnership
White Oak Farm, Inc.
604 Benton Pond Road
Fremont, North Carolina 27830
Subject: REVISED NOTICE OF VIOLATION/NOTICE OF INTENT TO.ENFORCE _and
NOTICE OF REGULATORY REQUIREMENTS
White Oak Farm #96-67
AWI960067
Wayne County
NOV-2022-PC-0329
Dear B & B Partnership:
The Division of Water Resources issued an initial Notice of Violation/Notice of Intent to Enforce (NOV-
2022-PC-0329) on July 5, 2022 for violations occurring at the above referenced facility. A response to
the initial Notice was received on July 18, 2022. The provided September 2, 2022 Notice serves as an
update to the original July 5, 2022 Notice:
On May 30, 2022, agents of the facility (White Oaks Farm Inc) reported to the Division of Water
Resources (DWR) about the failure of the digester cover (over the anaerobic earthen -lined digester)
resulting in the discharge of "foam" like waste material from the digester lagoon. DWR's Animal
Feeding Operations (AFO) staff made site inspections on May 30, May 31, June 3, and June 7, 2022,
including subsequent dates, confirming the discharge and observing the efforts made to contain the foam
waste. During site inspections, ruptures in the digester cover were identified and discharge and
accumulation of the foam product at the facility and into the surrounding environment were observed. The
foam discharge event started on May 30, 2022, and lasted until at least June 23, 2022 for a total of at
least 25 days.
Foam waste product was observed in surface waters and/or Nahunta Swamp on June 3, 2022. Abatement
measures were taken to address foam discharged to surface waters with no observed foam present on June
7, 2022. As of a site visit on June 23, 2022, foam waste product was still discharging from the anaerobic
earthen lined digester. Foam prodad-ucfua...-produet-residual-mass-was-still-located-in-are uutside of
the earthen -lined digester but not in surface waters. Abatement and recovery measures were taken to
address and mitigate the discharge and impacts.
ilepartmemverdinnateloadi
North Carolina Deportment of Environmental Quality Division of
Washington Regional Offiej 943 Washington Square Mall
Washington, North Carolina 27889
252-946-6481
ter Resourc

Based on the above incident, you are hereby notified that, having been permitted to have a non -discharge
permit for the subject animal waste disposal system pursuant to 15A NCAC 2T Section .1300, you have
been found to have improperly managed an animal waste management system resulting in a discharge of
pollutants to surface waters and wetlands in accordance with your Certified Animal Waste Management
Plan and the Individual Swine Animal Waste Management System General Permit No. AWI960067 that
you are covered to operate under. Violations related to the incident and facility management follow:
Violation 1: Failure to maintain and operate a non -discharge system to prevent discharges in
accordance with the facility's Certified Animal Waste Management Plan, and in accordance with
Condition I.1. of Individual Swine Waste Management System Permit No. AWI960067. Condition I.1.
states
"The animal waste collection, treatment, storage, and land application system permitted under this
Permit shall be effectively maintained and operated as a non -discharge system to prevent the discharge of
pollutants to surface waters, wetlands, or ditches. Waste shall not reach surface waters or wetlands by
runoff, drift, manmade conveyance, direct application, direct discharge or through ditches, terraces, or
grassed waterways not otherwise classified as state waters."
A discharge did occur from the system (covered digester lagoon) on and/or following the May 30, 2022,
incident, and proceeded to flow overland into the wetlands and open water of Nahunta Swamp and/or
tributaries.
Required Corrective Action for Violation 1: Take action to clean up all waste (foam) that was
discharged and bring the facility into compliance with permit conditions. Take all necessary steps to stop
the discharge. Take all necessary additional steps to properly operate and maintain the non -discharge
system to prevent future discharges. Address any and all violations that may be attributed to the
discharge.
Violation 2: Failure to update CAWMP and modify the facility's permit to reflect current operational
practices in accordance with Condition I.S. and Condition VII.15. of Individual Swine Waste
Management System Permit No. AWI960067. Condition I. 5. states: "Any violation of the CAWMP, the
Operation and Maintenance Plan, or the Monitoring Plan shall be considered a violation of this Permit
and subject to enforcement actions. A violation of this Permit may result in the Permittee having to take
immediate or long-term corrective action(s) as required by the Division. These actions may include but
are not limited to: modifying the CAWMP; ceasing land application of waste; or the Permit being
reopened and modified, revoked and reissued, and/or terminated. These actions may include but are not
limited to: ceasing use of the Innovative System, modifying operation of the Innovative System,
modifying the CAWMP, ceasing land application of waste, or removing animals from the Facility. [G.S.
§143-215.6A and 15A NCAC 02T .0110]
The facility has been operating without animals since December 2020 based on available information.
Condition VII.15 states, This Permit is effective only with respect to the nature and volume (at least fifty
percent animal waste) of wastes described in this Permit for the White Oak Farms. — [G.S. §143-215.1]
Required Corrective Action for Violation 2: The new CAWMP and the certification shall be
submitted with a request that the COC be amended to reflect the changes. The facility may not make the
changes until a new or amended COC has been issued. Once the covered lagoon has been approved to
return to operation, the facility must reestablish the proper composition of waste inputs to the system in
accordance with terms of permit.
2

Violation 3: Failure to conduct air quality monitoring in accordance with Condition I.8.b. and Condition
4.5. of Individual Swine Waste Management System Permit No. AWI960067. Condition I.8.b. states,
"NC General Statute §143-215.101 requires the Facility covered by this Permit satisfy the performance
criteria as prescribed in 1 SA NCAC 02T .1307-.1309 and 15A NCAC 02D .1808.
a. Facility must substantially reduce ammonia emissions.
i. The combined ammonia emissions from swine waste treatment and storage structures
may not exceed an annual average of 0.2 kg NH3-N/week/1, 000 kg of steady state
live weight (SSLW) which is 375 kg NH3-N/week for this facility in Phase 1 and 844
kg NH3-N/week for this facility in Phase 2.
ii. Ammonia emissions from land application sites shall not exceed an annual average
of 0.2 kg NH3-N/week/1, 000 kg of SSLW which is 375 kg NH3-N/week for this facility
in Phase 1 and 844 kg NH3-N/week for this facility in Phase 2.
iii. Total ammonia emissions from the swine farm must not exceed an annual average of
0.9 kg NH3-N/week/1,000 kg of SSLW which is 1685 kg NH3-N/week for this facility
in Phase 1 and 3798 kg NH3-N/week for this facility in Phase 2.
b. Compliance and monitoring with respect to odor intensity levels at the property boundary
shall be evaluated at both upwind and downwind locations of each treatment and animal
housing site using one of the following:
i. Use an Odor Intensity Referencing Scale (OIRS) as specified in ASTM544-99. All
instantaneous observed levels shall be less than the equivalent of225 parts per
million n-butanol. The average of 30 consecutive observations conducted over a
minimum of 30 minutes shall be less than the equivalent of 75 parts per million n-
butanol with a minimum offour (4) observations of the 30 less than or equal to the
equivalent of 25 parts per million n-butanol.
ii. Use a field olfactometry method and instrumentation. The measured dilution -to -
threshold ratio shall be less than or equal to 7:1 as determined using the
manufacturer 's instrument procedures and instructions.
Condition IV.5. (Paragraph 4) states, Ammonia air emissions from open-air structures and barns shall be
sampled quarterly.
Ammonia emissions were not measured in 2021 and the annual report states "because the animal numbers
were so low (50-81), the ammonia emissions will be so low compared to other waste sources".
Operational changes do not allow you to unilaterally decide which permit conditions are applicable.
Permit conditions continue to apply unless and until they are removed from the permit in accordance
proper permit modification procedures.
Required Corrective Action for Violation 3: Provide all quarterly sampling results for emissions.
Continue with the quarterly sampling.
Violation 4: Failure to demonstrate that there has been no release of disease -transmitting vectors and
airborne pathogens in accordance with Condition I.8.c. Condition I.8.c.i. of Individual Swine Waste
Management System Permit No. AWI960067 states, "Facility must substantially eliminate the release of
disease -transmitting vectors and airborne pathogens by meeting the following:
i. Fecal coliform concentrations in the final liquid effluent shall not exceed an annual average
of 7,000 Most Probable Number/100 mL."
Fecal samples have not been measured nor results reported per Condition I.8.c.i.
Pquutred-rnrrnr*iyp_An n A.a-i _Providroyi,1
ea-fer�ielatia C rcperts-

Violation 5: Failure to demonstrate compliance with the NRCS nutrient management standard as it
relates to phosphorus within 6 months of issuance of the facility's permit in accordance with Condition
I.9 Condition I.9. of Individual Swine Waste Management System Permit No. AWI960067 states
"The Permittee shall conduct an evaluation of the facility and its CAWMP to determine the facility's
ability to comply with the NRCS nutrient management standard as it relates to phosphorous within six (6)
months of issuance of this Permit. The evaluation must be documented on forms supplied by or approved
by the Division and must be submitted to the Division. The Permittee may submit documentation from a
previous evaluation if performed within five (5) years of the issuance of this Permit.
All fields with a "HIGH" phosphorous -loss assessment rating shall have land application rates that do not
exceed the established crop removal rate for phosphorous. There shall be no waste application on fields
with a "VERY HIGH" phosphorous -loss assessment rating." — [15A NCAC 02T .0108(c)]
Phosphorus documentation has not been provided for review.
Required Corrective Action for Violation 5: The Phosphorous evaluation must be submitted by
September 30, 2022.
Violation 6: Failure to properly operate and maintain the collection, treatment, and storage units at all
times -in -accordance with Condition I.13:-and Condition I1.1.
Conditions 1.13. of Individual Swine Waste Management System Permit No. AWI960067 states
"The Innovative System including the spray irrigation system shall be effectively maintained and
operated at all times so that there is no discharge to surface waters or any contamination of ground waters,
which will render them unsatisfactory for normal use. In the event that the Innovative System fails to
perform satisfactorily, including the creation of nuisance conditions or failure of the irrigation area to
adequately assimilate the wastewater, the Permittee shall take immediate corrective actions including
those actions that may be required by the Division."
Condition II.1. of Individual Swine Waste Management System Permit No. AWI960067 states
"The collection, treatment, and storage units and the land application equipment and fields shall be
properly operated and maintained at all times."
* The facility has operated beyond the scope of what is approved under the facility's permit, including
introduction of unapproved materials into the Innovative system (Digester).
* The anaerobic earthen -lined digester cover failed resulting in the release of wastes into the surrounding
environment and into the waters of the state. Waste has discharged from concrete structures (wet wells)
located on the western side of the digester.
* Air quality and odors observed over the incident were objectionable. Fugitive waste product foam was
uncontained beyond the digester structure.
* Accumulation of solids and sludge were observed within structures with minimal freeboard remaining
to safely contain product.
* Field observations indicate either prior or ongoing waste releases have impacted an area extending off
the southeastern corner of the digester structure continuing south towards Nahunta Swamp.
rouudwater rnumtulurg data utdtcates exce-edanc- ufi3A NCAC-2 g oundwater standards at
locations at or beyond the Compliance Boundary.
4

* The cover on the 970,000-gallon mesophilic tank digester is in disrepair.
Required Corrective Action for Violation 6: Take immediate corrective action to address each
identified item above in Violation 6.
Violation 7: Failure to manage solids, residuals, or sludges in accordance with Condition 11.14. of
Individual Swine Waste Management System Permit No. AWI960067. Condition 1I.14 states, "The
solids, residuals, or sludges generated from this Facility must be disposed in accordance with G.S. § 143-
215.1 and in a manner approved by Condition I.8.c of this Permit. When removal of sludge from the
treatment units is necessary, provisions must be taken to prevent damage to any dikes and liners.
The current system design does not address treatment of solids, residuals, or sludges to the above
referenced requirements; therefore, these materials must be transported to an offsite treatment facility
unless or until a Permit modification is submitted and approved.
If solids, residuals, or sludges accumulate faster than predicted, and it is determined that designed
treatment, storage and disposal methods are insufficient, the Permittee will immediately deactivate the
Innovative System, ceasing the generation of solids, until adequate solids storage and/or removal can be
designed, approved, and constructed."
Based on observed volumes of solids, residuals, or sludges present at the facility, and no available records
demonstrating solids/sludge removal and transporting to offsite treatment facilities, solids have not been
disposed of and managed at the facility. Additionally, actions to immediately deactivate the Innovative
System and cease generation of solids until conditions are acceptable did not occur.
Required Corrective Action for Violation 7: Submit details when the Innovative system was
deactivated and a plan of action for handling the solids, residuals, or sludges present.
Violation 8: Failure to limit introduction of unapproved materials into the Innovative System in
accordance with Condition 1II.2. of Individual Swine Waste Management System Permit No.
A WI960067. Condition I1I.2. states, "No material other than the following shall be disposed of in the
Innovative System or other components of the animal waste collection, treatment, storage, or application
systems. — [15A NCAC 02T .0108(b)]
a. animal wastes of the type generated on this facility,
b. up to 20,000 pounds/day of food waste (edible meat waste from Smithfield's Kinston plant); and
c. up to 105 tons/day of swine animal mortality"
Per the annual report submitted, the food waste far exceeded the allowable limit. Available information
indicates that in addition to animal waste, food waste (from Smithfield's Kinston Plant) and swine animal
mortality, guts, filler, peptone, and blood, liquid protein (lp?) have also been introduced into the system.
It is also unclear whether hot dog and deli products have originated from Smithfield's Kinston Plant.
Available information also lists multiple days where more than 20,000 pounds of food waste was received
and accepted by the facility.
See Attachment A at the conclusion of this document for a summary of noted dates where food waste
limits were exceeded based on provided information.
5

Required Corrective Action for Violation 8: See below.
Violation 9: Failure to update and revise nutrient content and volume in effluent to reflect actual nutrient
load in accordance with Condition III.11. Condition III.11. of Individual Swine Waste Management
System Permit No. AWI960067 states, "Six (6) months after mortality feed stocks are added to the
digester and the digester has again reached steady state, the nutrient content and volume in the effluent
from the Innovative System must reviewed and the CAWMP revised, if needed, to reflect actual nutrient
load based."
It has not been demonstrated (since start up) that nutrient content and volume in the effluent has been
reviewed and the CAWMP has not been updated to reflect any necessary revisions.
Required Corrective Action for Violation 9: Submit all applicable records that demonstrate review of
nutrient content and volume in the past 2 years.
Violation 10: Failure to submit a comprehensive Operation and Maintenance (0 & M) manual within 1
year of operation (due November 20, 2018) of the Innovative System in accordance with Condition VII.9
of Individual Swine Waste Management System Permit No. AWI960067 states
"After the Innovative System has _been in use for one (1) year (does not need to be consecutive) the
Permittee or their designee must submit a comprehensive Operation and Maintenance (O&M) manual if
the system isto remain operational. The O&M manual shall include the following minimum information:
a. As -built drawings,
b. A detailed description of the Innovative System,
c. Warranty information for all installed equipment and each major component,
d Inventory, functional descriptions, and complete operating instructions for all installed
equipment and each major component,
e. Instructions for start-up/shutdown as well as for calibration and adjustment of all installed
equipment and each major component,
f Recommended maintenance management system, including preventative and predictive
maintenance, for all installed equipment and each major component,
g. Contact information for local service companies as well as instructions for replacement of all
installed equipment and each major component,
h. Contact information for local contractors capable of performing emergency repairs, and
i. Contact information for regulatory and other agencies."
A comprehensive 0 & M manual has not been provided.
Required Corrective Action for Violation 10: Note: 0 & MManual was submitted on July 18, 2022.
Violation 11: Failure to submit a comprehensive operator training program for approval within 1 year of
operation (due November 20, 2018) of the Innovative System in accordance with Condition VII.10.
VII.10. of Individual Swine Waste Management System Permit No. AWI960067 states
"After the Innovative System has been in use for one (1) year (does not need to be consecutive) the
Permittee or a designee must submit a comprehensive operator -training program to be approved by the
Division."
A rnmprahanciva nperator training program has not been -submitted for review and approval.
6

Required Corrective Action for Violation 11: Note: Training program was submitted with 0 & M on
July 18, 2022.
Violation 12: Failure to operate the White Oak Farms facility with respect to the nature and volume of
wastes described in the permit in accordance with Condition VII.15. of Individual Swine Waste
Management System Permit No. AWI960067 which states, "This Permit is effective only with respect to
the nature and volume of wastes described in this Permit for the White Oak Farms.
Any proposed modification to an animal waste management system shall require approval from the
Division prior to construction."
Unapproved wastes have been accepted at the facility and approved volumes for acceptable receivables
has been exceeded as referenced in Violation 8 above.
Required Corrective Action for Violation 12: See below.
Violation 13: Failure to maintain a vegetative cover on areas receiving wastes and apply wastes only to
areas approved in the facility's CAWMP in accordance with Condition II.2. Condition II.2. of Individual
Swine Waste Management System Permit No. AWI960067 states
"A vegetativecover shall be maintained as specified in the facility's CAWMP on all land application
fields and buffers in accordance with the CAWMP. No waste shall be applied upon areas not included in
the CAWMP or upon areas where the crop is insufficient for nutrient utilization. However, if the CAWMP
allows, then waste may be applied up to thirty (30) days prior to planting or breaking dormancy."
Discharged foam accumulated in areas not approved for application per the CAWMP. Such unapproved
areas receiving wastes had no established vegetative cover.
Required Corrective Action for Violation 13: See below.
Violation 14: Failure to maintain freeboard levels in accordance with Condition II.1. Condition II.1.
of Individual Swine Waste Management System Permit No. AWI960067 states, The collection, treatment,
and storage units and the land application equipment and fields shall be properly operated and maintained
at all times. — [15A NCA 02T .1304(b)]
No available freeboard was observed in facility structures on May 30, 2022.
Required Corrective Action for Violation 14: Maintain freeboard levels in facility structures at or
below the designed freeboard levels.
Violation 15: Failure to comply with groundwater quality standards specified in 15A NCAC 2L .0202
and/or Interim Maxim Allowable Concentrations at or beyond the Compliance Boundary.
Groundwater monitoring data for monitoring wells MW-1 and MW-2 report the following levels for the
March 30, 2022, sampling event.
Date Sampled
Well
Ammonia
(mg/L)
(TMAC- 1.5
TKN (mg/L)
Nitrate (mg/L)
(2L�S\td = 10
R)
mgfL)
7

3/30/2022
MW-1
26.20
23.76
65.53
3/30/2022
MW-2
24.60
24.56
3.33
A review of the permit and Groundwater Monitoring Reports showed that total ammonia in Monitoring
Wells MW-I and MW-2 were above the groundwater standard at or beyond the Compliance Boundary.
Required Corrective Action for Violation 15:
The Division of Water Resources has reason to believe that B & B Partnership is responsible for activities
resulting in noncompliance with North Carolina law. B & B Partnership is producing and managing
wastes that can be characterized as containing elevated levels of nutrient compounds. The self -reported
sample reports for the above referenced wells have elevated concentrations of total ammonia at or beyond
the Compliance Boundary. This letter is to formally notify you of violations of 15A NCAC 2L
(Groundwater Quality Standards) and to advise you of what you are required to do to correct these
violations in accordance with 15A NCAC 2L .0106 (d).
According to 15A NCAC 2L .0106 (d) (1) the permittee shall demonstrate through predictive calculations
or modeling, that natural site conditions, facility design and operational controls will prevent a violation
of standards at the compliance boundary. Alternately, the person may submit a plan for alteration of
existing site conditions, facility design or operational controls that will prevent a violation at the
compliance_ boundary_ and implement that plan upon its approval by the Secretary.
If contaminants are detected at or beyond the compliance boundary, the permittee shall respond in
accordance with the requirements of 15A NCAC 2L .0106 (f). The permittee shall assess the cause,
significance, and extent of the violation of standards and submit the results of the investigation, and a plan
and propose a schedule for corrective action to the Division. The permittee shall implement the plan as
approved.
Also, according to 15A NCAC 2L .0106 (f) an initial response is required to be conducted prior to or
concurrent with the assessment required in 15A NCAC 2L .0106 (d). The permittee shall abate, contain,
or control the migration of contaminants. The permittee shall remove, treat or control the primary
pollution source. The site assessment shall be in accordance with 15A NCAC 2L .0106 (g) and the
corrective action shall be in accordance with 15A NCAC 2L .0106 (h).
Required Corrective Action for Violations 2 through 14: Take all necessary actions to comply with all
permit conditions, CAWMP requirements, and any other applicable regulatory requirements. Please work
to ensure that your facility is managed in a way to maintain compliance with permit and animal waste
management plan requirements. The discharge continued through at least June 23, 2022.
ADDITIONAL INFORMATION REQUEST:
1. In addition to violations cited above, the Division of Water Resources requests all records required to
be maintained per Condition IV.1. of the permit be provided with your response. Condition IV.1. of
Individual Swine Waste Management System Permit No. AWI960067 states, "Adequate records shall be
maintained by the Permittee to track the amount of sludge/separated solids that is disposed. These
records shall include but are not necessarily limited to the volume of sludge/separated solids generated
and dates and amounts of sludge/separated solids removed from the site."
condition IV Q s„bmit„ h of„ e _eho_�,�r,s,oive report every six month, ineluding-the-period from
January 1 — June 30.

Condition IV.8. of Individual Swine Waste Management System Permit No. AWI960067 states, 'A
comprehensive report shall be submitted to the Division every six months after initial start-up of the
Innovative System. Reports for January 1- June 30 are due by July 31, and Reports for July 1—
December 31 are due by January 31. The report shall consist of all records, logs, and reports as required
in Permit Conditions III.1 through III.7. The report shall be submitted to the Animal Feeding Operations
Program, 1636 Mail Service Center, Raleigh, NC 27699-1636 and to the Water Quality Regional
Operations Supervisor, Washington Regional Ofce, 943 Washington Square Mall, Washington, NC
27889. Upon prior approval, reports may be submitted electronically.
Please include your January 1 — June 30, 2022, comprehensive report with your response to this Notice.
(Received July 18, 2022 — resubmittal not required)
2. Areas where abatement and corrective action measures have been conducted have resulted in land
disturbance in areas within protected zones covered under Neuse River Riparian Buffer regulations
(50'buffer along surface waters and wetlands, in general). A Riparian Buffer Repair and Restoration Plan
to restore impacted areas within protected buffered areas shall be submitted within 45 days of receipt of
this Notice.
3. Condition IV.20. of Individual Swine Waste Management System Permit No. AWI960067 states,
"In the event of a discharge of 1,000 gallons or more of waste to surface waters or wetlands, the
Permittee must issue a press release to all print and electronic news media that provide general
coverage in the county in which the discharge occurred setting out the details ofthe discharge. The press
release must be issued within forty-eight (48) hours after it is determined that the discharge has reached
the surface waters or wetlands. A copy of the press release and a list of the news media to which it was
distributed must be kept for at least one (1) year after the discharge and must be distributed to any
person upon request."
Please provide documentation to support that press release requirements were satisfied.
You are required to take any necessary action to address the above violations. You are required to
provide a written response to this Notice, including any additional information that you wish to
provide related to this incident that you wish for the Division to consider, within 10 days of receipt
of this letter. Please include in your response all corrective actions already taken and a schedule for
completion of any corrective actions not addressed. Among items to include in your response, please also
reference the volume of wastes discharged from the covered earthen digester structure, volume of wastes
discharged to surface waters, and volumes recovered from surface waters.
Your response should also include a descriptive root cause analysis providing a supported conclusion
on what the foaming event was attributed to. Factors, actions, and mechanisms that contributed to the
foaming event should be provided as a detailed explanation on why the event occurred. Based on the
understanding of what caused the incident, recommendations shall be provided noting steps and actions to
be taken to prevent such incident from re -occurring.
The root cause analysis shall be performed by a party having appropriate background and expertise to
provide a qualified explanation for why the foaming incident occurred, ultimately causing the digester
cover rupture and discharge of waste. Credentials of the party performing the root cause analysis shall be
referenced to demonstrate their level of expertise, experience, and knowledge with such matters. The
presented root cause analysis shall be evaluated by the Division, along with operational conclusions and
recommendation¢ made to encore that curb foaming -incidents con ha preventeri from re_nrrnrrin nd the
facility can maintain compliance with permit conditions. Please note, until such time that the Division

concurs materials other than animal waste manure can be safely introduced into the digester
system, non -manure products are prohibited from introduction into the system. Your detailed root
cause analysis is a critical component in aiding the Division's evaluation of the matter, and as such,
should be weighted accordingly with your response.
Failure to comply with conditions in a permit may result in a recommendation of enforcement action, to
the Director of the Division of Water Resources who may issue a civil penalty assessment of not more
that twenty-five thousand ($25,000) dollars against any "person" who violates or fails to act in accordance
with the terms, conditions, or requirements of a permit under authority of G.S. 143-215.6A. To minimize
the potential for any possible future compliance matters attributable to prolonged wet weather conditions,
you may wish to review your animal waste management system design, as well as the waste plan itself,
for any potentially beneficial modifications and/or improvements.
Please note, as additional information becomes available, further action and/or response may be required
beyond the scope of items referenced in this letter.
We appreciate your attention and prompt response in this matter. If you have questions, please do not
hesitate to call Marlene Salyer at [phone].
Sincerely,_
David May, L.G., Supervisor
Water Quality Regional Operations Section
Division of Water Resources
Washington Regional Office
cc: DWR-WQROS-CAFO Unit -Central Office
Wayne County Soil and Water Conservation District
NCDSWC - WaRO
WaRO Compliance Animal Files
mds Files
10

4 CHMENT.A•tfuod Waste (Ibs)
Date" I '.. Poundslimit
(Ibs) " I
i n P
1/3/2022
37519
20,000
Hot Dogs
1/3/2022
29541
20,000
Deli
1/5/2022
25080
20,000
Deli
1/8/2022
46519
20,000
Hot Dogs
1/18/2022
78,136
20,000
Hot Dogs
1/18/2022
22141
20,000
Deli
1/19/2022
26801
20,000
Hot Dogs
1/19/2022
24842
20,000
Deli
1/27/2022
58231
20,000
Hot Dogs
1/27/2021
28143
20,000
Deli
2/1/2022
31343
20,000
Hot Dogs
2/2/2022
24377
20,000
Deli
2/3/2022
30732
20,000
Hot Dogs
2/7/2022
26145
20,000
Deli
2/_7/2022_
_ _ _28512
20,000
Hot Dogs
2/14/2022
21586
20,000
Hot Dogs
2/16/2022
53815
20,000
Hot Dogs
2/16/2022
27635
20,000
Deli
2/18/2022
23655
20,000
Deli
2/21/2022
24808
20,000
Hot Dogs
2/23/2022
33538
20,000
Hot Dogs
2/24/2022
22872
20,000
Deli
2/25/2022
24183
20,000
Hot Dogs
2/25/2022
29831
20,000
Deli
2/28/2022
23709
20,000
Hot Dogs
3/2/2022
20571
20,000
Deli
3/8/2022
20335
20,000
Hot Dogs
3/9/2022
27256
20,000
Hot Dogs
3/10/2022
20475
20,000
Deli
3/17/2022
22464
20,000
Deli
3/17/2022
26793
20,000
Hot Dogs
3/18/2022
22548
20,000
Deli
3/21/2022
38547
20,000
Deli
3/22/2022
33229
20,000
Hot Dogs
3/31/2022
26263
20,000
Hot Dogs
4/4/2022
61188
20,000
Hot Dogs
4/4/2022
52020
20,000
Deli
4/7/2022
25203
20,000
Deli
4/11/2022
24646
20,000
Hot Dogs
4/13/2022
30658
20,000
Deli
4/14/2022
21330
20,000
Hot Dogs
4/18/2022
27221
20,000
Deli
4/20/2022
30086
20,000
Hot Dogs
4/21/2022
28892
20,000
Deli

4/25/2022
27740
20,000
Hot Dogs
4/27/2022
26160
20,000
Deli
5/6/2022
45822
20,000
Hot Dogs
5/10/2022
48043
20,000
Deli
5/11/2022
21629
20,000
Hot Dogs
5/16/2022
23459
20,000
Deli
5/17/2022
24400
20,000
Hot Dogs
5/18/2022
28953
20,000
Hot Dogs
5/19/2022
25466
20,000
Hot Dogs
5/24/2022
25268
20,000
Deli