820283_NOV-2020-PC-0429 Packet with Pictures (R)_20201001

NOTICE OF VIOLATION/NOTICE OF INTENT PACKET
ROBERT ALLEN THROTON FARM
MS.CORNELIA FORD
AWS820283
NOV-2020-PC-0429

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NOTICE OF VIOLATION AND/OR
NOTICE OF INTENT

R.OY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
September 29, 2020
CERTIFIED MAIL
RETURN RECEIPT REQUESTED 7019 0700 0000 3643 1342
Robert Allen Thornton Farm
Ms. Cornelia Ford
259 Ethan En
Clinton NC 28328-8086
Subject: NOTICE OF VIOLATION/NOTICE OF INTENT
Administrative Code 15A NCAC 2T .1304
NOV-2020-PC-0429
Incident number 202002628
Robert Allen Thornton Farm Facility Number 82-283
Permit AWS820283
Sampson County
Dear Ms. Ford:
On September 14, 2020, staff of the NC Department of Environmental Quality (DEQ) Division
of Water Resources (DWR), Water Quality Regional Operations Section (WQROS) inspected
the Robert Allen Thornton Farm and the permitted waste disposal system.
As a result of this inspection, 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 .1304,
you have been found to be in violation of your permit as follows:
Violation 1:
Failure to maintain the maximum waste level in lagoons/storage ponds that shall not exceed that
specified in the facility's CAWMP. At a minimum, maximum waste level for lagoons/storage
ponds must not exceed the level that provides adequate storage to contain the 25-year, 24-hour
storm event plus an additional one (1) foot of structural freeboard except that there shall be no
violation of this condition if:
Page 2
:Varna Carolina De par talent of Environmental Quality Division of Water Re ]urres
Fayetteville Regional Off re 1225 Green Street, Suite i I4 Fayetteville. North Carolina 23301
9104333300

Ms. Cornelia Ford
September 29, 2020
a. there is a storm event more severe than a 25-year, 24-hour event;
b. the Fermittee is in compliance with its CAWMP and
c. there is at least one (1) foot of structural freeboard. — f15A NCAC 02T .1304(b)].
(Permit No. AWG100000 Section V2)
On September 14, 2020, DWR received an email containing aerial pictures of your farm, and
they documented ponded waste around the flexible hose at your irrigation pump. DWR
documented that the ponded area was still there but none had left the field. DWR staff did
document your lagoon level was 18.5 inches, and the minimum designed lagoon level is 19
inches. Based on the time stamp of the aerial photo you were purnping around 11:00 am, and
when DWR staff arrived at 5:50pm, your irrigation pump was still running. Based on the debris
on top of the horizontal pipe, DWR concluded your level prior to pumping was 17 inches or less.
Required Corrective Action for Violation 1:
Follow 30-day plan of actions provided to the DWR. In the future maintain your waste level in
accordance with your facility's CAWMP. Take all necessary additional legal steps to insure
lagoon levels remain in compliance with Section (V2) of your permit_
Violation 2:
The Permittee shall report by telephone to the appropriate Division Regional Office as soon as
possible, but in no case more than twenty-four (24) hours following first knowledge of the
occurrence of any of the following events:
e. Failure to maintain storage capacity in a lagoon/storage pond greater than or equal to
that required in Condition V. 2. of this General Permit. (Permit AWG No.100000 Section
17 e).
Your permit specifically requires notification by telephone within 24 hours and a written report
within 5_calenrlar nays following first knowledge of the orcuxrrn of a reportable permit
condition. DWR has no record of receiving the 24-hour notification and the 5-day written report..
On September 14, 2020 as noted above in violation 1, DWR documented that your lagoon was
non -compliant. Based on the debris on top of the horizontal pipe on your lagoon marker the
lagoon level was less than 17inches for more than 24 hours prior to DWR site visit.

Page 3
Ms. Cornelia Ford
September 29, 2020
Required Corrective action for Violation 2:
In the event of a high freeboard situation, call the regional office within twenty-four (24) hours
of the first knowledge of the high freeboard. Prepare and submit within 48 hours a 30 day a Plan
of Action (POA) for lowering the lagoon/storage pond to an acceptable level as described in your
CAWMP and General Permit.
Violation 3;
Failure to maintain a protective vegetative cover on all earthen lagoon/storage pond
embankments (outside toe of embankment to maximum operating levellcompliance level on
embankment interior). Lagoon /storage pond areas shall be accessible, and vegetation shall be
kept mowed. [ I SA NCAC 02T .1304(b)]. (Permit AWG 100000 Section II Condition 12).
On SeprP bank had not been mowed and no
vegetative cover has been established on the bare areas of your lagoon. The vegetation on the
lagoon bank prevent proper inspection of the embankment. Both of these issue were noted in
your May 15, 2019 routine compliance inspection.
Required Corrective action for Violation 3:
Mow your lagoon banks and repair any erosion and seed all bare areas of the lagoon bank within
90 days.
The Division of Water Resources requests that, in addition to the specified corrective action
above, please submit the following items on or before (October 31, 2020:
1. An explanation from the OIC for this farm regarding how these violations occurred.
2. A list from the OIC concerning the steps that will be taken to prevent these violations
from occurring in the future.
3. A copy of your pumping rvcnrdlr fnr the 7070 Bermuda crop and freeboard levels and
rainfall for 2020
You are required to take any necessary action to correct the above violations on or before
December 31, 2020 and to provide a written response to this Notice by October 31, 2020.
Please include in your response all corrective actions already taken and a schedule for
completion of any corrective actions not addressed.

Page 4
Ms. Cornelia Ford
September 23, 2020
As a result of the violations in this Notice, this office is considering a recommendation for a civil
penalty assessment to the Director of the Division. If you wish to present an explanation for the
violations cited, or if you believe there are other factors, which should be considered, please send
such information to me in writing within ten 00) days following receipt of this letter. Your
response will be reviewed, and, if an enforcement action is still deemed appropriate. it will be
forwarded to the Director and included for consideration.
Failure to comply with conditions in a permit may result in a recommendation of enforcement
action, to the Director of the Division of Water Quality 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.
If you have any questions concerning this Notice, please contact Steve Guyton at (910)-303-0151
or me at [phone].
Sincerely,
(--DocuSigntA by::
- antIL
5189C203€CF5C428...
J. Trent Allen
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources
cc: DWR - WQROS - CAFO Unit --- Central Office
PRO Compliance Animal Files-Laserfiche
?restage Farms

_ as
Facility No. Time In . 3-7-3 Time Out 6 -S- Date c)L )1-
Farm Name p}iFn f i - Fas- - Integrator
Owner -- FV,`1 Site Rep
Operator No.
Back-up No.
COC Circle: General or NPDES
Design
Current
Design
Current
Wean - Feed
Farrow - Feed
Wean - Finish
Farrow - Finish
Feed - Finish
Gilts / Boars
Farrow - Wean
Others
FREEBOARD: Design
Observed
Crop Yield
Rain Gauge
Soil Test Wettable Acres
Sludge Survey
Calibration/GPM 1
Waste Transfers
Rain Breaker
PLAT
Weekly Freeboard Daily Rainfall 1-in Inspections
Spray/Freeboard Drop
Weather Codes 120 min Inspections
Waste Analysis:
Date Nitrogen (N)
Date Nitrogen (N)
Pull/Field
Soil
Crop
Pan
Window
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INSPECTION REPORT / NOTES

Onsite Representative:
Certified Operator:
Back-up Operator:
Location of Farm:
Facility Number
Division of Water Resources
Division of Soil and Water Conservation;'
0 Other Agency
9 3 ,
Type of Visit: Compliance Inspection 0 Operation Review 0 Structure Evaluation 0 Technical Assistance
Reason for Visit: 0 Routine e1 omplaint 0 Follow-up 0 Referral 0 Emergency 0 Other 0 Denied Access
Date of Visit:
Arrival Time:
Farm Name: , `t/77 .
Owner Name: L
frd
{ `.. 074 Departure Time:
L , `3SYn.
Owner Email:
Phone:
County: Region:
Mailing Address:
Physical Address:
Facility Contact: (r' t,-7, �;�r "/ J Title: 82CZ2 Y'<" Phone:
r it z-e,.
Latitude:
Integrator:
Certification Number:
Certification Number:
Longitude:
Swine
Wean to Finish
Wean to Feeder
Feeder to Finish
Farrow to Wean
Farrow to Feeder
Farrow to Finish
Gilts
Boars
Other
Design Current
Capacity Pop.
Other
Design Current
Wet Poultry Capacity Pop. Cattle
Layer
Non -Layer
Design Current
Fr Ca , aci Po
Designs,, Current
Capacit Pop.
Discharges and Stream Impacts
1. Is any discharge observed from any part of the operation?
Discharge originated at: ❑ Structure ❑ Application Field ❑ Other:
a. Was the conveyance man-made? ❑ Yes ❑ No ❑ NA ❑ NE
b. Did the discharge reach waters of the State? (If yes, notify DWR) ❑ Yes ❑ No ❑ NA ❑ NE
c. What is the estimated volume that reached waters of the State (gallons)?
d. Does the discharge bypass the waste management system? (If yes, notify DWR) n Yes ❑ No ❑ NA ❑ NE
2. Is there evidence of a past discharge from any part of the operation? n Yes 0'"1Vo ❑ NA ❑ NE
3. Were there any observable adverse impacts or potential adverse impacts to the waters n Yes Q'No ❑ NA ❑ NE
of the State other than from a discharge?
❑ Yes DIN() ❑ NA ❑ NE
Page 1 of 3
2/4/2015 Continued

Date of Inspection: —
Waste Collection & Treatment
4. Is storage capacity (structural plus storm storage plus heavy rainfall) less than adequate?
a. If yes, is waste level into the structural freeboard?
Identifier:
Spillway?:
Designed Freeboard (in):
Observed Freeboard (in):
El Yes ❑ No ❑ NA ❑ NE
❑Yes ErVd ❑NA ❑NE
Structure 1 Structure 2 Structure 3 Structure 4 Structure 5 Structure 6
5. Are there any immediate threats to the integrity of any of the structures observed? ❑ Yes [ No ❑ NA ❑ NE
(i.e., large trees, severe erosion, seepage, etc.)
6. Are there structures on -site which are not properly addressed and/or managed through a ❑ Yes L No ❑ NA ❑ NE
waste management or closure plan?
If any of questions 4-6 were answered yes, and the situation poses an immediate public health or environmental threat, notify DWR
7. Do any of the structures need maintenance or improvement?
8. Do any of the structures lack adequate markers as required by the permit?
(not applicable to roofed pits, dry stacks, and/or wet stacks)
9. Does any part of the waste management system other than the waste structures require
maintenance or improvement?
Waste Application
10. Are there any required buffers, setbacks, or compliance alternatives that need
maintenance or improvement?
11. Is there evidence of incorrect land application? If yes, check the appropriate box below.
[.es ❑ No ❑ NA ❑ NE
❑ Yes ❑`No ❑ NA ❑ NE
❑ Yes iNo ❑ NA ❑ NE
n Yes n No ❑ NA []`NE
❑ Yes ❑ No ❑ NA []ENE
❑ Excessive Ponding ❑ Hydraulic Overload n Frozen Ground ❑ Heavy Metals (Cu, Zn, etc.)
❑ PAN ❑ PAN > 10% or 10 lbs. ❑ Total Phosphorus ❑ Failure to Incorporate Manure/Sludge into Bare Soil
❑ Outside of Acceptable Crop Window ❑ Evidence of Wind Drift ❑ Application Outside of Approved Area
12. Crop Type(s):
13. Soil Type(s):
14. Do the receiving crops differ from those designated in the CAWMP? n Yes ❑ No ❑ NA (`jNE
15. Does the receiving crop and/or land application site need improvement? nYes ❑ No ❑ NA ❑ NE
16. Did the facility fail to secure and/or operate per the irrigation design or wettable ❑ Yes ❑ No ❑ NA Q'TIE
acres determination?
17. Does the facility lack adequate acreage for land application? n Yes ❑ No ❑ NA 1*_
18. Is there a lack of properly operating waste application equipment? n Yes [a'1\io ID NA ( NE
Required Records & Documents
19. Did the facility fail to have the Certificate of Coverage & Permit readily available? n Ycs ❑ No ❑ NA ❑-'NE
20. Does the facility fail to have all components of the CAWMP readily available? If yes, check n Yes ❑ No ❑ NA Q'1\IE
the appropriate box.
❑ WUP ['Checklists ❑ Design ❑ Maps D Lease Agreements ['Other:
21. Does record keeping need improvement? If yes, check the appropriate box below. ❑ Yes ❑ No ❑ NA aNE
❑ Waste Application ❑ Weekly Freeboard ❑ Waste Analysis ❑ Soil Analysis ❑ Waste Transfers ❑ Weather Code
❑ Rainfall ❑ Stocking ❑ Crop Yield ❑ 120 Minute Inspections ❑ Monthly and 1" Rainfall Inspections ❑ Sludge Survey
22. Did the facility fail to install and maintain a rain gauge? n Yes ❑ No ❑ NA Er -NE
23. If selected, did the facility fail to install and maintain rainbreakers on irrigation equipment? n Ycs ❑ No ❑ NA E NE
Page 2 of 3 2/4/2015 Continued

Facility Number: ,L - '`j
1Date of Inspection: 7- J f 4 2c)
24. Did the facility fail to calibrate waste application equipment as required by the permit?
❑ Yes ❑ No ❑ NA
25. Is the facility out of compliance with permit conditions related to sludge? If yes, check ❑ Yes ❑ No ❑ NA
the appropriate box(es) below.
❑ Failure to complete annual sludge survey [] Failure to develop a POA for sludge levels
D Non -compliant sludge levels in any lagoon
List structure(s) and date of first survey indicating non-compliance:
a E
26. Did the facility fail provide documentation of an actively certified operator in charge? ❑ Yes ❑ No ❑ NA 2'5-F,
27. Did the facility fail to secure a phosphorus loss assessments (PLAT) certification? ❑ Yes ❑ No ❑ NA El-i IF
Other Issues
28. Did the facility fail to properly dispose of dead animals with 24 hours and/or document ❑ Yes ❑ No ❑ NA [] NE
and report mortality rates that were higher than normal?
29. At the time of the inspection did the facility pose an odor or air quality concern? ❑ Yes �No ❑ NA ❑ NE
If yes, contact a regional Air Quality representative immediately.
30. Did the facility fail to notify the Regional Office of emergency situations as required by the I3 Yes ❑ No ❑ NA ❑ NE
permit? (i.e., discharge, freeboard problems, over -application)
31. Do subsurface tile drains exist at the facility? If yes, check the appropriate box below. ❑ Yes ❑ No ❑ NA E NE
❑ Application Field ❑ Lagoon/Storage Pond ❑ Other:
32. Were any additional problems noted which cause non-compliance of the permit or CAWMP? ❑ Yes Erio ❑ NA L NE
33. Did the Reviewer/Inspector fail to discuss review/inspection with an on -site representative? ❑ Yes [] No L NA ❑ NE
34. Does the facility require a follow-up visit by the same agency? Efies ❑ No ❑ NA ❑ NE
Comments (refer to question #): Explain any YES answers and/or any additional recommendations or any other comments.
Use drawings of facility to better explain situations (use additional pages as necessary).
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Reviewer/Inspector Name:
Phone: �J1�'3 �3 �e7 L5 I
Reviewer/Inspector Signature:
Date:
Page 3 43 2/4/2015

VIOLATORS RESPONSE AND NOTES

Guyton, Steve
From: Cornelia Ford <[e-mail]>
Sent: Wednesday, November 11, 2020 11:11 AM
To: Guyton, Steve
Subject: [External] Letter
Dear Mr. Steve,
As of today, I still haven't heard anything. So, just so I know you have it in writing...
I do apologize for not calling in on lagoon. I've always been good about that. Mr. Dunlap can vouch for
me. But we have had a tougher than normal year. The day you were here, a new fuel pump had just been put
on. It was picked up that day. The second one in as many months. First one did not last two pulls. Prior to
that, there have been 3 or 4 starters (I've lost count)put on same engine in last six months or so. The last one
just a couple of weeks before you were here. Between having parts rebuilt and waiting on parts to come in, it
was not pumped as it normally would have been. Irrigation was running ,as you saw when you were here, and
has been in compliance since that day. I was not aware level had gotten under 19 as I have been laid up with a
severe leg injury. Open wound and broken to boot. And trying to get things done and not giving me more
stress, my sons have been doing their best. But not necessarily keeping me informed on everything and I had
something to say about that.. Hopefully I will be up and out before long...hopefully.
Steps are being taken, as per our conversations, to address the bare spots on the lagoon dam. Also talked with
extension agent.
Again. I apologize for any aggravation this may have caused you. I will do my best to keep things in order in
the future.
Sincerely,
Cornelia Ford
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