090100_NOV-2021-DV-0266 Enforcement Packet w photos_20210915

NOTICE OF VIOLATION AND/OR
NOTICE OF INTENT

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
July 20, 2021
CERTIFIED MAIL
RETURN RECEIPT REQUESTED 7010 1870 0003 4775 0747
Oak Springs Sow Farm LLC
PO Box 2979
Elizabethtown, NC 28337
Subject: NOTICE OF VIOLATION/NOTICE OF INTENT
Administrative Code 15A NCAC 2T .1304
NOV-2021-DV-0266
Oak Springs Sow Farm LLC 09-100
Permit AWS090100
Bladen County
Dear Oak Springs Sow Farm LLC,
On May 20, 2021, staff of the NC Department of Environmental Quality (DEQ) Division of
Water Resources (DWR), Water Quality Regional Operations Section (WQROS) inspected the
Oak Springs Sow Farm LLC and the permitted waste disposal system. We wish to thank Mr.
Geno Kennedy for his assistance during this inspection.
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:
The collection, treatment and storage facilities, and the land application equipment and fields shall be
properly operated and maintained at all times. — [15A NCAC 02T. 1304(b)]. (Permit No. AWG100000
Section Conditions II 1)
On May 20, 2021, DWR staff was conducting a routine compliance inspection and while walking around
the lagoon, DWR staff noticed wastewater was ponding around the pump hook-up hydrant and was
flowing from the hydrant at the pump. DWR staff was able to document with pictures that the wastewater
was coming from the butterfly valve at the pump, and at the time the pump was not running. After further
investigation, DWR staff documented with samples and pictures that the waste had entered the woods and
the ditch behind the farm which went into a wetland area.
LD_E
NORTH CAROLINA
Dena�rent a EnufrommoMai Ouaaty
North Carolina Department of Environmental Quality 1 Division of Water Resources
Fayetteville Regional Office 225 Green Street, Suite 714 1 Fayetteville, North Carolina 28301
910.433.3300

Page 2
Oak Springs Farm Sow Farm LLC
July 20, 2021
Required Corrective Action for Violation 1:
In the future, monitor the permitted storage facilities and collections systems. In the event that there is
waste that leaves your storage facility or waste collection system, contain the waste and prevent waste
from leaving and entering surface waters. Waste should never be allowed to flow into surface waters
intentionally. In the future, the employees need to report any issues with the system to management, and
in addition, training on how to operate the irrigation system, and install preventative devices to prevent
accidental discharges. Not limited to but possible Best Management Practices would be a back flow
device in the irrigation line and a containment area around this hydrant to capture any waste so it can be
returned to the lagoon.
Violation 2:
Any discharge of waste that reaches surface waters or wetlands is prohibited except as otherwise provided
in this General Permit and associated statutory and regulatory provisions. 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. [ G.S.143-215.10C]
(Permit No. AWG100000 Section Conditions I 1).
On May 20, 2021 during the site evaluation, DWR staff was able to document with pictures that there was
waste coming from the butterfly valve at the pump, and at the time the pump was not running. Waste was
flowing into the ditch located behind the lagoon that flows out into the woods. DWR staff documented
with pictures and water samples that the waste entered the ditch in the woods which flowed to and
collected in the wetland area. Later in the afternoon on May 20, 2021, a follow up inspection was
conducted by DWR staff to document the recovery of waste from the ditch and wetlands. Farm staff were
actively cleaning up waste and completed the task while DWR staff was on site. This was documented
with pictures.
Required Corrective action for Violation 2:
In the future, valves need to be checked before leaving the area and turned off, and the OIC needs to
check equipment after a pumping event to make sure equipment is operating properly. In the future if any
waste reaches surface waters or wetlands, report the findings to DWR immediately and try to recover as
much as waste as possible. DWR would like to thank your farm staff for the quick recovery of the
waste.
Violation 3:
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:
D_E
NORTH CAROUNA
North Carolina Department of Environmental Quality j Division of Water Resources
Fayetteville Regional Office 225 Green Street, Suite 714 j Fayetteville, North Carolina 28301
910.433.3300
Onpmbnenl of Environmanlal Quality

Page 3
Oak Springs Sow Farm LLC
July 20, 2021
A. Failure of any component of the animal waste management system resulting in a discharge to
diches, surface waters, or wetlands. — [15A NCAC 02T. 1304(b)]. (Permit No. AWG100000
Section Conditions III 17 A).
Your permit specifically requires notification by telephone within 24 hours and a written report
within 5 calendar days following first knowledge of the occurrence of a reportable permit
condition. DWR has no record of receiving the 24-hour notification and the 5-day written report
concerning the discharge of waste from your hydrant pump.
On May 20, 2021 during your compliance inspection, DWR staff documented with pictures and water
samples and that latter confirmed waste did enter the ditch beside the lagoon which flowed to and
collected in a wetland area. Geno Kennedy the Technical Specialist informed the OIC that the discharge
had occurred.
Required Corrective action for Violation 3:
In the future, notify DWR staff at first knowledge of the occurrence of any issues such as discharge from
the storage facilities or waste collection systems.
Violation 4:
The OIC, a designate Back-up OIC of a Type A Animal Waste Management System, or a person
under the supervision of an OIC or designated Back-up OIC shall inspect the land application
site as often a necessary to ensure that the animal waste is land applied in accordance with the
CAWMP. In no case shall the time between inspections be no more 120 minutes during the land
application of waste. A record of each inspection shall be recorded on forms supplied by, or
approved by, or approved by, the Division and shall include the date, time, land application area
used, and name of the operator for each inspection. If neither the OIC or designated Back-up
OIC was present during land application, the OIC or designated Back-up OIC shall inspect the
land application area within twenty-four (24) hours.
Inspection shall include but not be limited to visual observation of equipment, land application
area, subsurface drain outlets, ditches, and drainage ways for any discharge of waste. [15A
NCAC 8F.0203(b) and 15A NCAC 02T .0108(c)] (Permit No. AWG100000 Section II
Conditions 17).
D_E
NORTH CAROUNA
North Carolina Department of Environmental Quality j Division of Water Resources
Fayetteville Regional Office 225 Green Street, Suite 714 j Fayetteville, North Carolina 28301
910.433.3300
Onpmbnenl of Environmanlal Quality

Page 4
Oak Springs Sow Farm LLC
July 20, 2021
DWR staff arrived on site at 11:15am on May 20,2021. During the discovery of a discharge,
Geno Kennedy the Technical Specialist informed the OIC there was a discharge at the pump
where it had been discharging since the last pumping event. The waste had run down the hill and
entered the ditch beside the farm. DWR documented with pictures and samples that the waste has
indeed entered the ditch and wetland beside the farm.
On May 20, 2021 during the follow-up inspection, the OIC did not arrive to the farm until after
1:30 pm during the recovery of the waste.
Required corrective action for Violation 4:
The OIC or designated OIC needs to check equipment after every pumping event. Your permit
states that land application and equipment should be inspected within twenty-four (24) hours
after a pumping event by the OIC.
Violation 5:
Crops for which animal waste is land applied must be harvested, removed from the land
application site, and properly managed and utilized unless other management practices are
approved in the CAWMP. Hay harvested from land application fields shall be removed within
twenty-four (24) months of cutting unless other management practices are approved in the
CAWMP. — [15A NCAC 02T.0108(b) and .1304(b)] (Permit No. AWG100000 Section II
Condition 28)
During the Compliance Inspection on May 20, 2021, it was documented with pictures that the
crops on the irrigation fields had not been harvested. There were no records during the
inspection for crop yields for those field.
Required corrective action for Violation 5:
Crops must be harvested from the land application field.
The Division of Water Resources requests that, in addition to the specified corrective action
above, please submit the following items within 30 days of receipt of this letter:
D_E
NORTH CAROUNA
North Carolina Department of Environmental Quality j Division of Water Resources
Fayetteville Regional Office 225 Green Street, Suite 714 j Fayetteville, North Carolina 28301
910.433.3300
Onpmbnenl of Environmanlal Quality

Page 5
Oak Springs Sow Farm LLC
July 20, 2021
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.
You are required to take any necessary action to correct the above violations within 30
days of receipt of this letter and to provide a written response to the Fayetteville Regional
Office.. Please include in your response all corrective actions already taken and a schedule for
completion of any corrective actions not addressed.
Please note that assessment of civil penalties may have already been recommended for violations
described within this Notice of Violation. Failure to comply with the State's rules, in the manner and
time specified, may result in the assessment of additional civil penalties and/or the use of other
enforcement mechanisms available to the State.
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 Diane Harrison [phone]
or me at [phone].
Sincerely,
DocuSignedd by: _
5189C2D3DD5C42B...
J. Trent Allen
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources
cc: FRO Compliance Animal Files-Laserfiche
Smithfield Pork
D_E
NORTH CAROUNA
North Carolina Department of Environmental Quality j Division of Water Resources
Fayetteville Regional Office 225 Green Street, Suite 714 j Fayetteville, North Carolina 28301
910.433.3300
Onpmbnenl of Environmanlal Quality

INSPECTION REPORT / NOTES

Division of Water Resources
❑ Division of Soil and Water Conservation
❑ Other Agency
Facility Number: 090100
Facility Status: Active
Permit: AWS090100 ❑ Denied Access
Inspection Type: Compliance Inspection Inactive Or Closed Date:
Reason for Visit: Routine
County:
Bladen
Region:
Date of Visit: 05/20/2021 Entry Time: 08:30 am Exit Time: 11:30 am Incident #:
Farm Name: Oak Springs Sow Farm
Owner: Oak Springs Sow Farm LLC
Mailing Address: 1122 Oberlin Rd
Owner Email:
Fayetteville
Phone: [phone]
Raleigh NC 27605
Physical Address: 1141 Allen Priest Rd Council NC 28434
Facility Status: ❑ Compliant • Not Compliant
Integrator: Murphy -Brown LLC
Location of Farm: Latitude: 34° 31' 53"
9 mi. south of Hwy. 87, right on SR 1714, 1 mi. on left.
Longitude: 78° 29' 25"
Question Areas:
▪ Dischrge & Stream Impacts
▪ Records and Documents
▪ Waste Col, Stor, & Treat
▪ Other Issues
Waste Application
Certified Operator:
Secondary OIC(s):
Leslie L Stutts
Operator Certification Number: 20897
On -Site Representative(s): Name Title Phone
24 hour contact name Geno Kennedy
On -site representative Geno Kennedy
Primary Inspector:
Inspector Signature:
Diane Harrison
Secondary Inspector(s):
Katie Fontenot
Steve Guyton
Phone: [phone]
Date:
Inspection Summary:
#1 waste was flowing into a ditch beside the lagoon the waste discharged from the valve of the pump & hydrant. DWR took
samples . recover waste & return to lagoon
#30 notify DWR of a discharge
#15 remove cover crop
#9 make sure hydrant & pumps are not leaking
On May 20, 2021 from 1:30pm - 3:00pm Steve Guyton did a follow-up inspection to document the cleanup of waste in the woods
and wetlands, from an earlieer inspection on 5-20-2021.
Farm staff were actively recovering waste with buckets from the ditch and wetlands when I arrived.
Mr. Leslie Stutts the OIC came on secne and helped the staff finish recovery. They recovered as much as possiblewith buckets
and front end loader and returned waste to the lagoon.
This was documented with pictures. no futher clean up is required some waste in the wetland was unrecoverable.
Page 1 of 6

Permit: AWS090100
Inspection Date: 05/20/21
Owner: Oak Springs Sow Farm LLC Facility Number: 090100
Inspection Type: Compliance Inspection Reason for Visit: Routine
Mr Stutts said he would talk with the employee about cuting valve off. we also talked about the removeal of the oversee, which
needed to be done as soon as possible.
Page 2 of 6

Permit: AWS090100
Inspection Date: 05/20/21
Owner: Oak Springs Sow Farm LLC Facility Number: 090100
Inspection Type: Compliance Inspection Reason for Visit: Routine
Regulated Operations
Design Capacity
Current promotions
Swine
Swine - Farrow to Wean
Waste Structures
Type
1,808
1,800
Identifier
Effective
Date
Total Design Capacity:
Total SSLW:
Built
Date
1,808
782,864
Closed Designated Observed
Date Freeboard Freeboard
Lagoon
09-100-1
05/25/2005
10/01/2019
19.00
54.00
Lagoon
1
10/25/2005
19.50
Page 3 of 6

Permit: AWS090100
Inspection Date: 05/20/21
Owner: Oak Springs Sow Farm LLC Facility Number: 090100
Inspection Type: Compliance Inspection Reason for Visit: Routine
Discharges & Stream Impacts
1. Is any discharge observed from any part of the operation?
Discharge originated at:
Structure
Application Field
Other
a. Was conveyance man-made?
b. Did discharge reach Waters of the State? (if yes, notify DWQ)
c. What is the estimated volume that reached waters of the State (gallons)?
d. Does discharge bypass the waste management system? (if yes, notify DWQ)
2. Is there evidence of a past discharge from any part of the operation?
3. Were there any observable adverse impacts or potential adverse impacts to Waters of the
State other than from a discharge?
Waste Collection, Storage & Treatment
4. Is storage capacity less than adequate?
If yes, is waste level into structural freeboard?
5. Are there any immediate threats to the integrity of any of the structures observed (I.e./ larc
trees, severe erosion, seepage, etc.)?
6. Are there structures on -site that are not properly addressed and/or managed through a
waste management or closure plan?
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 application?
If yes, check the appropriate box below.
Excessive Ponding?
Hydraulic Overload?
Frozen Ground?
Heavy metals (Cu, Zn, etc)?
PAN?
Is PAN > 10%/10 lbs.?
Total Phosphorus?
Failure to incorporate manure/sludge into bare soil?
Outside of acceptable crop window?
Evidence of wind drift?
Application outside of application area?
Yes No NA NE
• ❑ ❑ ❑
❑ • ❑ ❑
• ❑ ❑ ❑
❑ • ❑ ❑
❑ • ❑ ❑
❑ • ❑ ❑
Yes No NA NE
❑ • ❑ ❑
❑ • ❑ ❑
❑ • ❑ ❑
❑ • ❑ ❑
❑ • ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
❑ • ❑ ❑
❑ • ❑ ❑
Page 4 of 6

Permit: AWS090100
Inspection Date: 05/20/21
Owner: Oak Springs Sow Farm LLC Facility Number: 090100
Inspection Type: Compliance Inspection Reason for Visit: Routine
Waste Application
Crop Type 1
Crop Type 2
Crop Type 3
Crop Type 4
Crop Type 5
Crop Type 6
Soil Type 1
Soil Type 2
Soil Type 3
Soil Type 4
Soil Type 5
Soil Type 6
14. Do the receiving crops differ from those designated in the Certified Animal Waste
Management Plan(CAWMP)?
15. Does the receiving crop and/or land application site need improvement?
16. Did the facility fail to secure and/or operate per the irrigation design or wettable acre
determination?
17. Does the facility lack adequate acreage for land application?
18. Is there a lack of properly operating waste application equipment?
Records and Documents
19. Did the facility fail to have Certificate of Coverage and Permit readily available?
20. Does the facility fail to have all components of the CAWMP readily available?
If yes, check the appropriate box below.
WUP?
Checklists?
Design?
Maps?
Lease Agreements?
Other?
If Other, please specify
21. Does record keeping need improvement?
If yes, check the appropriate box below.
Waste Application?
Weekly Freeboard?
Waste Analysis?
Soil analysis?
Waste Transfers?
Weather code?
Rainfall?
Yes No NA NE
Bermuda Grass (Hay,
Pasture)
Small Grain Overseed
Wagram
❑ • ❑ ❑
• ❑ ❑ ❑
❑ • ❑ ❑
❑ • ❑ ❑
Yes No NA NE
❑ • ❑ ❑
❑ • ❑ ❑
❑❑❑❑❑❑❑
Page 5 of 6

Permit: AWS090100
Inspection Date: 05/20/21
Owner: Oak Springs Sow Farm LLC Facility Number: 090100
Inspection Type: Compliance Inspection Reason for Visit: Routine
Records and Documents
Stocking?
Crop yields?
120 Minute inspections?
Monthly and 1" Rainfall Inspections
Sludge Survey
22. Did the facility fail to install and maintain a rain gauge?
23. If selected, did the facility fail to install and maintain a rainbreaker on irrigation equipmen
(NPDES only)?
24. Did the facility fail to calibrate waste application equipment as required by the permit?
25. Is the facility out of compliance with permit conditions related to sludge? If yes, check the
appropriate box(es) below:
Failure to complete annual sludge survey
Failure to develop a POA for sludge levels
Non -compliant sludge levels in any lagoon
List structure(s) and date of first survey indicating non-compliance:
26. Did the facility fail to provide documentation of an actively certified operator in charge?
27. Did the facility fail to secure a phosphorous loss assessment (PLAT) certification?
Other Issues
28. Did the facility fail to properly dispose of dead animals within 24 hours and/or document
and report mortality rates that exceed normal rates?
29. At the time of the inspection did the facility pose an odor or air quality concern? If yes,
contact a regional Air Quality representative immediately.
30. Did the facility fail to notify regional DWQ of emergency situations as required by Permit
(i.e., discharge, freeboard problems, over -application)
31. Do subsurface tile drains exist at the facility?
If yes, check the appropriate box below.
Application Field
Lagoon / Storage Pond
Other
If Other, please specify
32. Were any additional problems noted which cause non-compliance of the Permit or
CAW M P?
33. Did the Reviewer/Inspector fail to discuss review/inspection with on -site representative?
34. Does the facility require a follow-up visit by same agency?
Yes No NA NE
El
El
❑ • ❑ ❑
El
El
❑ • ❑ ❑
Yes No NA NE
❑ • ❑ ❑
❑ • ❑ ❑
❑ • ❑ ❑
❑ • ❑ ❑
Page 6 of 6

52fG, A- dd caw--9
Facility Number
/9C
GrI iivision of Water Resources
O Division of Soil and Water Conservation
0 Other Agency
Type of Visit: ®ompliance Inspection 0 Operation Review 0 Structure Evaluation 0 T'echnical Assistance
Reason for Visit: 0 Routine 0 Complaint e-Follow-up
Date of Visit: J---- G,'{3?/Arrival Time: /' - Departure Time:
Farm Name: ('a I \ , 5f2t; n `5-vw Faint
Owner Name: � fS (5, 7_c5.0a /'Y)'(. LL6 Phone:
0 Referral 0 Emergency 0 Other 0 Denied Access
County: 3 Region:
3No
Owner Email:
Mailing Address:
Physical Address:
Facility Contact: nD � Title: 7— , ,� e -G, Phone:
Onsite Representative:
Certified Operator:
Back-up Operator:
Location of Farm:
Latitude:
Integrator:
Certification Number:
Certification Number:
Longitude:
Swine
Design Current
Capacity Pop.
Wean to Finish
Wean to Feeder
Feeder to Finish
Farrow to Wean
Farrow to Feeder
Farrow to Finish
Gilts
Boars
Other
Design Current
Wet Poultry Capacity Pop.
Layer
Non -Layer
Design Current
Dry Poultry Capacity Pop.
Layers
Non -Layers
Pullets
Turkeys
Turkey Poults
Other
Cattle
Design Current
Capacity Pop.
Dairy Cow
Dairy Calf
Dairy Heifer
Dry Cow
Non -Dairy
Beef Stocker
Beef Feeder
Beef Brood Cow
Discharges and Stream Impacts
1. Is any discharge observed from any part of the operation?
Discharge originated at: ❑ Structure ❑ Application Field
Other:
❑ .es ❑ No ❑ NA ❑ NE
JT (— o)- Lam
a. Was the conveyance man-made? ❑ Yes ❑ No ❑ NA ❑ NE
b. Did the discharge reach waters of the State? (If yes, notify DWR) 1.14'es ❑ No ❑ NA [1 NE
c. What is the estimated volume that reached waters of the State (gallons)? rj -A
d. Does the discharge bypass the waste management system? (If yes, notify DWR) LYes ❑ No ❑ NA ❑ NE
2. Is there evidence of a past discharge from any part of the operation? ❑ Yes a<o ❑ NA ❑ NE
3. Were there any observable adverse impacts or potential adverse impacts to the waters ri Yes 21<lo ❑ NA [1 NE
of the State other than from a discharge?
Page 1 of 3
5/12/2020 Continued

Facility Number: g- - /VO
Date of Inspection:—P-
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):
Structure 1 Structure 2
Structure 3 Structure 4
5. Are there any immediate threats to the integrity of any of the structures observed?
(i.e., large trees, severe erosion, seepage, etc.)
6. Are there structures on -site which are not properly addressed and/or managed through a
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
❑ Yes
❑ Yes
Structure 5
❑ No ❑ NA ❑"NE
El No El NA RIVE
Structure 6
❑ Yes ❑ No ❑ NA [-NE
❑ Yes ❑ No 0 NA
7. Do any of the structures need maintenance or improvement? ❑ Yes ❑ No
8. Do any of the structures lack adequate markers as required by the permit? ❑ Yes ❑ No
(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 ❑ Yes ❑ No
maintenance or improvement?
Waste Application
10. Are there any required buffers, setbacks, or compliance alternatives that need ❑ Yes ❑ No ❑ NA
maintenance or improvement?
11. Is there evidence of incorrect land application? If yes, check the appropriate box below. ❑ Yes ❑ No ❑ NA alCit-
❑ Excessive Ponding ❑ Hydraulic Overload ❑ 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):
❑ NA
❑ NA
RisTt
R-1crE
❑ NA ENE
14. Do the receiving crops differ from those designated in the CAWMP?
15. Does the receiving crop and/or land application site need improvement?
16. Did the facility fail to secure and/or operate per the irrigation design or wettable
acres determination?
17. Does the facility lack adequate acreage for land application'?
18. Is there a lack of properly operating waste application equipment?
Required Records & Documents
19. Did the facility fail to have the Certificate of Coverage & Permit readily available?
20. Does the facility fail to have all components of the CAWMP readily available? If yes, check
the appropriate box.
n WUP n Checklists ❑ Design n Maps ❑ Lease Agreements
21. Does record keeping need improvement? If yes, check the appropriate box below.
n Yes ❑ No ❑ NA ETIC1
n Yes ❑ No ❑ NA iE
❑ Yes ❑ No ❑ NA II E
❑ Yes ❑ No ❑ NA I NE
n Yes ❑ No ❑ NA Er<
n Yes
n Yes
n Other:
n Yes
❑ No ❑ NA NE
El No ❑NA
❑ No El NA
la -KC
n Waste Application ❑ Weekly Freeboard n Waste Analysis n Soil Analysis n Waste Transfers ❑ Weather Code
n Rainfall ❑ Stocking n Crop Yield n 120 Minute Inspections n Monthly and 1" Rainfall Inspections ❑ Sludge Survey
22. Did the facility fail to install and maintain a rain gauge? ❑ Yes 0 No ❑ NA NE
23. If selected, did the facility fail to install and maintain rainbreakers on irrigation equipment? ❑ Yes El No El NA INE
Page 2 of 3 2/4/2015 Continued

Facility Number: - / p o
Date of Inspection:
24. Did the facility fail to calibrate waste application equipment as required by the permit?
❑ Yes ❑ No ❑ NA 2E
25. Is the facility out of compliance with permit conditions related to sludge? If yes, check ❑ Yes ❑ No ❑ NA LJ"1`ir
the appropriate box(es) below.
❑ Failure to complete annual sludge survey ❑ Failure to develop a POA for sludge levels
❑ Non -compliant sludge levels in any lagoon
List structure(s) and date of first survey indicating non-compliance:
26. Did the facility fail provide documentation of an actively certified operator in charge? ❑ Yes ❑ No ❑ NA 13-1 i-E
27. Did the facility fail to secure a phosphorus loss assessments (PLAT) certification? n Yes ❑ No 0 NA Is1E
Other Issues
28. Did the facility fail to properly dispose of dead animals with 24 hours and/or document ❑ Yes ❑ No ❑ NA 12--E
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 ❑ 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
❑ Application Field ❑ Lagoon/Storage Pond ❑ Other:
32. Were any additional problems noted which cause non-compliance of the permit or CAWMP?
33. Did the Reviewer/Inspector fail to discuss review/inspection with an on -site representative?
34. Does the facility require a follow-up visit by the same agency?
O Yes [o ❑ NA ❑ NE
❑ Yes RNo ❑ NA ❑ NE
❑ Yes Ef l`'o ❑ 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).
47° nvilow-Gcr
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Reviewer/Inspector Name:
Reviewer/inspector Signature:
Page 3of3
Phone: 0�3°,3
Date: L j ''C2 '2-)
2/4/2015

SAMPLE RESULTS/DATA

ANALYTICAL & CONSULTING CHEMISTS
NCDEQ/DWR-Fayetteville
225 Green Street
Fayetteville NC 28301
Attention: Katie Fontenot
Lab ID
21-20344
Test
Sample ID:
Site: Source
Fecal Coliform
Lab ID
21-20345
Test
Sample ID:
Site: Confluent
Fecal Coliform
Lab ID
21-20346
Test
Sample ID:
Site: Downstream
Fecal Coliforn1
Comment
Reviewed by:
viroe tal Chemists, Inc.
66 2 Wing mill Way, Will?i toy 3 NC 28405 9I.0.392 0223-Lab 910,392,4424 Fax
710 Bowsertown Roar , artte°, NC 27954 252.4715702 Lab/Fax
2 5 A Wilmington Highway„ „ Jacksonvillea NC 23540 s 910.34 .5843 Lab/Fax
Method
SM 9222D MF
Method
SM 9222D MF
Method
SM 9222D MF
r
nrnent: lchernasla.cur
Date of Report: May 24, 2021
Customer PCB #:
Customer ID: 19020022
Report #: 2021-08213
Project ID: 9-100 Oak Spring
Collect Date/Time Matrix
5/20/2021 11:53 AM Water
Collect Date/Time
Results
Sampled by
Fontenot/Dian
Date Analyzed
460000 Colonies/100mL 05/20/2021
Matrix
5/20/2021 11 '59 AM Water
Collect Date/Time
5/20/2021
Results
Matrix
Sampled by
Fontenot/Dian
Date Analyzed
350000 Colonies/100mL 05/20/2021
Sampled by
12:04 PM Water Fontenot/Dian
Results Date Analyzed
310000 Colonies/100mL 05/20/2021
Page 1 of 1

'
Environmental Chemist, Inc., Wilmington, NC Lab #94
Client:.
6602V0ndrnU|VVay
Wilmington, NC 28405
9I0.392O223
Sample Receipt Checklist
�
u
Receipt ofsample: _ECHEK4 Pickup
YES
[] NO
N/A
YES
[] NO
N/A Original temperature upon re'ceip
Report Q.
Client De|iverv[]
ere custody seals present on the cooler?
2. If custody seals were present, were they in tact/un broken?
I Corrected temperature upon receipt
How temperatlure taken: 0 Temperature Blank Against Bottles
|R Gun ID: Thomas Traceab|eS/N 192511657 {R6un Correction Factor ~C. 0.0
O YES O NO 3 If temperature -of cooler exceeded 6"C, was Project M
°
YES__ ![] NO4. Were proper custody procedures (relinquish ed/neceive )foUo .d?
YES
|O NO
YES
6,, Were samples ID's listed on -sample container
|O NO
NO 7 Were collection date and time listed on the COC?
YE
� YES [] NO B. Were tests tnbepe f
YES [] NO 9 Did samples arrive in proper containers for each test? '
YES
YES
YES
O NO . lO. Did samples arrive in good condition
--for
---s-?
[]_ NO _ |11. Was adequate sa mple vo/urne available?
12, Were samples received within proper holding tirne for requested tes'ts?
13.
ere acid preserved samples received at a pH of <2?
4. Were cyanide samples received at a pH > 12?
15. Were sulfide samples received at a pH >9?
16. Were NH3/TKN/Phenol received at a chlorine residual of <0,5 m
'
7
� Were ou/nosY at a chlorine residual of<O.5 rn/L7
I8.Were orthophosphate samples filtered inthe field within ISminutes?
** Bacteria samples are checked for Chlofine at time Of arla(Y51S and recorded on the bench5heet,
Sample Preservation,
addiTime of preservation:
ng (circle
Sample(s)
by
onei
ustbecompleted for any samp|e(s)incorre��y pese�dorwi----
� �nncaoupace/
were received incorrectly preserved and were adjusted accordingly
Hz504 HNO3 M[/ NaOH
If more than one preservative is needed, notate in comments below
Note: Noti
� customer service immediately for incorrectly preserved samples, Obtain a new sample or
notnythe state iabifdirected toana�yzedbvthe customer, Who was notified, date arid time:
\/o{ah|esSamp|e
COMM
ENTS:were received with headspace
DO[ QA.00Z Rev�

Analytical
Client:
ADDRESS:
Consultirn
Chemists
L
1
i
NCDENR: DWQ CERTIFICATION # 94 NCDHH : DLS CERTIFICATION # 37729
COLLECTION AND CHAIN OF CUSTODY
PROJECT NAME: cfh 1 0
CONTACT NAME:
REPORT TO:
COPY TO:
apled By:,'; i.:.
; j SA �yla t` TYPE:
Collection _
Sample identification . E a., o
(3 co o
Date Time Temp
c_, ca
G
6602 Windmill Way Wilmin€ tr ra, NC 28405
OFF10E; 910-392-0223 FAX [phone]
Infe environnentalche ists,com
REPORT NO:
Pa NO:
PHONE/FAX:
ail:
of cent, E = Effluent, W = Well, ST = Strea
1
SO = Sail, = Sludge. Other;
PRESERVATION
a
ANALYSIS REQUESTED
0
G
0 P
G
P
0
P
0
P
.i
Trans
Temperature when Received "C:
Delivered By:
Comments:
Relinquished By: DatefTirne
Accepted:
Received By:
Received By:
.Rejected:
Resample Requested:
_Date: Time:
TURNAROUND:
date/Time

VIOLATORS RESPONSE AND NOTES

RbUEIV
DEQ/DWR
JUN 0 2 i021
WQROS
FAYETTEVIIIE.REG QII1ALOFF►CE
KAIZEN FARMS
May 30th, 2021
North Carolina Department of Environmental Quality
Division of Water Resources
Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville, NC 28301
Attention Mr. Steve Guyton:
Subject: In response to the observation at Oak Springs Sow Farm
On Thursday, March 20th during an annual inspection at Oak Springs Sow Farm with the address
of 1141 Allen Priest Rd, Council, NC 28434 in Bladen County a leak from a hydrant was noted.
The following took place:
• The spill was immediately ceased by closing the butterfly valve
• A Trap was dug by Kaizen consultant to prevent any more wastewater
from occurring
• All wastewater was removed from the catch basin and all liquid were
taken back to the lagoon.
• The cleanup was inspected by the DWR-FRO and reports indicate that
was satisfactory
• Additional training was taken with the person responsible on March
21'
• After further inspection by the Operations Director the decision
was made to replace the butterfly valve which will be done the
week of 6/1/2021. We made the decision to do this as we had not
had any prior issues with the valve and felt that it would be
better to have the valve higher from ground level.
Respectfully,
Veedtae€ ?cadre,/
Director of Operations
910-379-8822 Mobile
[e-mail]

KAIZEN FARMS
May 30th, 2021
North Carolina Department of Environmental Quality
Division of Water Resources
Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville, NC 28301
Attention Mr. Steve Guyton:
Subject: In response to the observation at Oak Springs Sow Farm
On Thursday, March 20th during an annual inspection at Oak Springs Sow Farm with the address
of 1141 Allen Priest Rd, Council, NC 28434 in Bladen County a leak from a hydrant was noted.
The following took place:
• The spill was immediately ceased by
• A Trap was dug by Kaizen consultant
from occurring
• All wastewater was removed from
taken back to the lagoon.
• The cleanup was inspected by
was satisfactory
• Additional training was
21st_
• After further inspection by the Operations Director the
was made to replace the butterfly valve which will be done
week of 6/1/2021. We made the decision to do this as we had
had any prior issues with the valve and felt that it would be
better to have the valve higher from ground level.
Respectfully,
/t e€ %awl
Director of Operations
910-379-8822 Mobile
[e-mail]
the
the
closing
the
butterfly
to prevent any more
valve
wastewater
catch basin and all liquid were
DWR-FRO and reports
taken with the
person
indicate that
responsible
on March
decision
the
not

KAIZEN FARMS
August 17th, 2021
North Carolina Department of Environmental Quality
Division of Water Resources
Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville, NC 28301
Attention Mr. Trent Allen:
CC: Bladen County Soil and Water Conservation District
Subject: In response to the Notice of Violation
Administrative Code 15A NCAC 2T .1304
NOV-2021-DV-0266
Oak Springs Sow Farm LLC 09-100
Permit AWS090100
Bladen County
Mr. Allan,
REGLivtu
DEQ/D WR
AUG2....,
S"k2MI
WPAYED-El/4A FP NC
AI.OFFI ,
E
Please let this letter serve as our official response to the notice of violation we received dated July 20th,
2021 (NOV-2021-DV-0266) for the above referenced incident.
Response to Violation #1:
We agree with the statement "the collection, treatment, and storage facilities, and the land application
equipment and fields shall be properly operated and maintained at all times" and feel that we have done
so. There was no indication of prior (systemic) ponding around the butterfly valve as the volume of
effluent cleaned up was less than a 5-gallon bucket would hold and had just occurred. We also feel that
the statement including the word "intentionally" does not accurately represent the facts of the matter.
Corrective Action for Violation # 1:

o Kaizen took it's on initiative to raise and replace the valve to ensure that it can be closed
with adequate effort. A picture is attached for verification.
Response to Violation #2:
The area was cleaned up using (1) 5-gallon bucket in a short period of time. We strongly disagree with
the statement using the word "flowing". Given the short period of time it took to clean up and the minor
volume of wastewater (less than 5 gallons), these facts contradict the characterization that the water was
flowing.
Corrective Action for Violation # 2:
• The valve had been checked the afternoon prior to the day of the inspection and there was no
ponding present at this time. This was verified by the OIC and Production Management of the
site. As mentioned above, the valve has been replaced.
Response to Violation #3:
We apologize for the break down in communication on this item. The item of concern was found during
a routine inspection by DWR so we did not report the item as DWR was already aware of the item since
they were onsite and witnessed it in our presence. The defective/leaking valve was replaced immediately.
Corrective Action for Violation #3:
• Kaizen feels strongly that we are compliant with the requested corrective action for this item.
There is no evidence that Kaizen is not compliant with this item.
Response to Violation #4:
The Oil, anci Designee were compliant with the observation period as the system had been shut down the
afternoon prior to the day of the inspection. There was no observation of any ponding around the
butterfly valve at the time the system was shut down.
Corrective Action for Violation #4:
• DWR was present on site within the 24-hour period after the pumping event so we see no
violation with the time/timing as the shutdown had been done the afternoon prior which was
well within the 24 hours.

Response to Violation #5:
We respectfully disagree with the suggestion that we are not compliant with the harvest of crops. I have
attached pictures of the last harvest which was completed when the weather allowed for this. We had
already harvested earlier in the Spring which met the required date. The observation of the inspector on
this day of May 20th was "Regrowth" and has been harvested again.
Summary:
Kaizen takes great pride in the maintenance and care of its facilities and land. We have reviewed each of
the noted items with the OIC and his designee. We would like to note that this communication is a normal
on -going occurrence within the Kaizen system. Kaizen is dedicated to continuous improvement and is
committed to complying with all rules and regulations. Kaizen has also hired an Land and Nutrient Team
Manager in order to continue to the improvements.
Signatures of the OIC and designee are below.
We thank you in advance for your time and consideration and look forward to continuing to work closely
with you in the future.
r
Respectfully,
Director of Operations
910-379-8822 Mobile
[e-mail]
(1414,0/10AA:a Grr
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