090016_ENFORCEMENT_20171231

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State of North Carolina
Department of Environment -
and Natural ResourcesL__-_. �
Division of Water Quality A i�dn N=m E d =1 0 0 ��i
James B. Hunt, Jr., Governor NCDENR
Wayne McDevitt, Secretary NORTH CAROUNA DEPARTMENT OF
A. Preston Howard, Jr., P.E., Director ENVIRONMENT ANo NAa-uRAL RESOURCES
October 16, 1998
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Attn: Ray Reason, Jr.
Reason One Swine Farm
P.O. Box 3301
Elizabethtown, NC 28337
SUBJECT: Assessment of Civil
Penalties for Violation(s)
G. S 143-215.1
Bladen County
Farm # 09-16
File No. DD 98-011
Dear Mr. Reason:
This letter transmits notice of a civil penalty assessed against Ray Reason, Jr. in the .
amount of $4,460.49 including $460.69in investigative costs. Attached is a copy of the
assessment document explaining this penalty.
This action was taken under the authority vested in me by delegation provided by the
Secretary of the Department of Environment and Natural Resources. Any continuing violation(s)
may be the subject of a new enforcement action, including an additional penalty.
Within thirty days of receipt of this notice, you must do one of the following.
Submit payment of the penalty:
Payment should be made directly to the order of the Department of
Environment and Natural Resources (do not include waiver form).
Payment of the penalty will not foreclose further enforcement action for
any continuing or new violation(s).
Please submit payment to the attention of:
Ms. Coleen Sullins
Water Quality Section Chief
Division of Water Quality
P.O. Box 29535
Raleigh, North Carolina 27626-0535
OR
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

2. Submit a written request for remission or mitigation including a
detailed justification for such request:
A request for remission or mitigation is limited to consideration of the
reasonableness of the amount of the penalty and is not the proper procedure
for contesting the accuracy of any of the statements contained in the
assessment letter. Because a remission request forecloses the option of an
administrative hearing, such a request must be accompanied by a waiver of
your right to an administrative hearing and a stipulation that there are no
factual or legal issues in dispute. You must execute and return to this
office the attached waiver and stipulation form and a detailed statement
which you believe establishes whether:
(a) one or more of the civil penalty assessment factors in G.S. 143B-
282.1(b) were wrongfully applied to the detriment of the petitioner,
(b) the violator promptly abated continuing environmental damage resulting
from the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining
necessary remedial actions.
Please submit this information to the attention of:
Ms. CoIeen Sullins
Water Quality Section ChieflDWQ
P.O. Box 29535
Raleigh, North Carolina 27626-0535
Please note that all information presented in support of a request for
remission must be submitted in writing. The Director of the Division of
Water Quality will review the information during a bimonthly enforcement
conference and inform you of his decision in the matter of the remission
request. His response will provide details regarding case status and
provision for further appeal to the Environmental Management
Commision's Committee on Civil Penalty Remissions. Please be advised
that the Committee cannot consider information that was not part of the
original remission request considered by the Director and therefore, it is
very important that you prepare a complete and thorough statement in
support of your request -for remission.
OR
3. Submit a written request for an administrative hearing:
If you wish to contest any portion of the civil penalty assessment, you must
request an administrative hearing. This request must be in the form of a written
petition to the Office of Administrative Hearings and must conform to Chapter
150B of the North Carolina General Statutes. You must:

.0
C. The above -cited failure to maintain the liquid level in the lagoon at the level
specified in the CAWMP violated Condition No. V. 3. of the NPDES General
Permit.
D. The above -cited failure to report by telephone to the appropriate Regional Office
as soon as possible, but in no case more than 24 hours following first knowledge
of the occurrence of failure to maintain storage capacity in a lagoon/storage pond
greater than or equal to that required in Condition No_ V. 3 violated Condition No.
III. 11 '. e f of the NPDES- General Pehit. _
E_ The above -cited failure to provide the information requested in the Notices of
Violation dated September 16, 2004 and October 12, 2004 violated Condition No.
11I. 19. of the General Permit.
F. Ray Reason may be assessed civil penalties pursuant to G.S. 143-215.6A(a)(2)
which provides that a civil penalty of not more than twenty-five thousand dollars
($25,000.00) per violation may be assessed against a person who violates or fails
to act in accordance with the terms, conditions, or requirements of a permit
required by G.S. 143-215.1.
G. The State's enforcement costs in this matter may be assessed against Ray Reason
pursuant to G.S. 143-215.3(a)(9) and G.S. 14 3 B-2 82. 1 (b)(8).
H. The Chief of the Aquifer Protection Section, Division of Water Quality, pursuant
to delegation provided by the Secretary of the Department of Enviromnent and
Natural Resources and the Director of the Division of Water Quality, has the
authority to assess civil penalties in this matter.
Based upon the above Findings of Fact and Conclusions of Law, I make the following:
IIl. DECISION:
Ray Reason is hereby assessed a civil penalty of:
$_ 1, V a car a 0 for violating Condition No. V. 3. of the General Permit by
failing to maintain the liquid level in the lagoon at the level
specified in the CAWMP
$_ D D 0 , 0 7 for violating Condition No. 11I. 11. e. of the General Permit
by failing to report by telephone to the appropriate Regional
Office as soon as possible, but in no case more than 24
hours following first knowledge of the occurrence of failure
to maintain storage capacity in a lagoon/storage pond
greater than or equal to that required in Condition No. V.3.

t
File your original petition with the:
Office of Administrative Hearings
P_O. Drawer 27447
Raleigh, North Carolina 27611-7447
and
Mail or hand -deliver a Copy of the petition to:
Dan McLawhorn
Office of General Counsel
NCDENR
Post Office Box 27687
Raleigh, NC 27611
Failure to exercise one of the options above within thiqy days, as evidenced by a
date stamp (not a postmark) indicating when we received your response, will result in
this matter being referred to the Attorney General's Office with a request to initiate a
civil action to collect the penalty_ Please be advised that additional assessments may be
levied for future violations which occur after the review period of this assessment_
If you have any questions, please contact Mr. Shannon Langley at (919) 733-
5083, extension 581.
Sincerely,
A Preston Howard, Jr_, P.E.
ATTACHMENTS
cc: Regional Supervisor w/ attachments
Compliance/Enforcement File w/ attachments
.Central Files w/ attachments
Public Information Officer w/attachments

u
STATE OF NORTH CAROLINA
COUNTY OF
EIWIRONVIENTAL MANAGEMENT
COMNUSSION
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN .
OF CIVIL. PENALTIES AGAINST } ADrYM iISTRATIYE HEARING AND
PERMIT NO. } STIPULATION OF FACTS
FILE NO.
Having been assessed civil penalties totaling for
violation(s) as set forth in the assessment document of the Director of the Division -of Water Quality
dated, , the undersigned, desiring to seek remission of the civil
penalties, does hereby waive the right to an administrative hearing in the above -stated matter and
does stipulate that the facts are as alleged in the assessment document_
This the day of
TELEPHONE

STATE OF NORTH CAROLINA NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
COUNTY OF BLADEN
File No. DD 98-011
IN THE MATTER OF
)
RAY REASON, JR.
)
} FINDINGS AND DECISION
FOR MAKING AN OUTLET TO THE
} AND ASSESSMENT OF
WATERS OF THE STATE OF
) CIVEL PENALTIES
NORTH CAROLINA
)
WITHOUT A PERMIT
Acting pursuant to delegation provided by the Secretary of the Department of Environment
and Natural Resources, I, A. Preston Howard, Jr., Director of the Division of Water Quality
(DWQ), make the following:
1. FP;DINGS OF FACT:
A. Ray Reason, Jr. operates the Reason One Swine Farm, a swine animal operation in
Bladen County.
B. On February 11, 1998, DWQ staff observed that the application of animal waste onto
saturated spray fields resulted in excessive ponding and runoff to an adjacent
wooded area. Waste runoff from the wooded area was observed entering a ditch.
Waste in the ditch was observed discharging to Horseshoe Swamp, which are Class
"C - Sw" waters of the State within the Lumber River Basin.
C. The Reason One Swine Farm had no valid permit for the above -described activity.
D. The cost to the State of the enforcement procedures in this matter totaled S460.49.
Based upon the above Findings of Fact, I make the following:
11. CONCLUSIONS OF LAW:
A. Ray Reason, Jr. is a "person" within the meaning of G.S. 143-215.6A pursuant to
G.S. 143-212(4).
B_ Horseshoe Swamp constitutes waters of the State within the meaning of G.S_ 143-215.1
pursuant to G.S. 143-212(6).

r
.C. The above -cited discharge constituted making an outlet to waters of the State for
proposes of G.S. 143-215.1(a)(1), for which a permit is required by G.S. 143-215.1.
D. Ray Reason, Jr. may be assessed civil penalties in this matter pursuant to G.S. 143-
215.6A(a)(2), which provides that a civil penalty of not more than ten thousand
dollars (S 10,000.00) per violation may be assessed against a person for failing to act
in accordance with the terms, conditions or requirement of a permit required by G.S.
143-215.1.
E. The State's enforcement costs in this matter may be assessed against Ray Reason, Jr.
pursuant to G.S. 143-215.3(a)(9) and G.S. 143B-282. I (b)(8).
F. The Director, Division of Water Quality, pursuant to delegation provided by the
Secretary of the Department of Environment and Natural Resources, has the
authority to assess civil penalties in this matter.
Based upon the above Findings of Fact and Conclusions of Law, I make the following:
M. DECISION:
Accordingly, Ray Reason, Jr. is hereby assessed a civil penalty of:
$ L41600.00 for making an outlet to the waters of the State without a
permit as required by G.S. 143-215.1.
S 14 , O O o - 0 0 TOTAL CIVIL PENALTY, which is _�Q percent of the
maximum penalty authorized by G.S_ 143-215.6A.
$ 460.49 Enforcement costs
S +, i"- '4 g TOTAL AMOUNT DUE
As required by G.S. 143-215.6A(c), in determining the amount of the penalty I have considered the
factors listed in G.S.143B-282. I (b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;

,..
(S) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
(8) The cost to the State of the enforcement procedures.
(Date) Preston Howard, Jr., P.E., Director
Division of Water Quality

TRANSMISSION REPORT
( JAN 23 ' 99 - 02 : 00PM )
* DATE STAP.T REMOTE TERMINAL MODE
TIME RESULTS TOTAL DEFT. FILE
* TIME IDENTIFICATION
PANS CODE NO.
JAI 28 0I = 57PM ENV I RONIENTAL MGMT G3E ST
, 02' 44" OK 08 c
*
xc

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr-, P-E., Director
1 � •
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT ANo NATURAL RESOURCES
WATER QUALITY SECTION
NON -DISCHARGE BRANCH
COMPLIANCE & ENFORCEMENT UNIT
FAX NUMBER (919-715-6048)
TO: F'Q +-. ` ' _ Q 1-j if
FAX NLTIMBER: 2
FROM:
NUMBER OF PAGES INCLUDING THIS SHEET: 16
COMMENTS:
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative action Employer 30% recycled/10%a post -consumer paper

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f r s
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
AQUIFER PROTECTION SECTION
April 26, 2010
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
M and A Phillips, LLC
903 Wards Bridge Rd.
Warsaw, NC 28398
Subject: NOTICE OF DEFICIENCY
$laden Twentv Sites 1 and 2
A W S090016
Bladen County
NOD-201 O-PC-0510/ Incident No. 201000557
Dear Mr. Phillips:
On February 8, 2010, staff of the NC Division of Water Quality (DWQ), Aquifer Protection Section
(APS) were notified by Marshall Phillips of a high freeboard level in the lagoon 1. We wish to thank
Mr. Phillips for notifying DWQ of this incident.
As a result of this 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 be in violation of your Certified Animal Waste Management Plan and the Swine Waste
System General Permit No. AWG 100000 that you are covered to operate under, as follows:
Deficiency 1:
Failure to maintain waste levels in your lagoon/storage ponds in accordance with the facility's Certified
Animal Waste Management Plan in accordance with Condition V. 2. of Swine Waste System General
Permit No. AWG 100000.
On February 8, 2010 a lagoon/storage pond level was documented at 18.75 inches in lagoon 1. A level
of 19 inches is the maximum level allowed by your permit and Certified Animal Waste Management
Plan.
North Carolina Division of Water Quality Internet: www.ncwaterguality_org
225 Green St., Ste. 714 Phone: [phone]
Fayetteville, NC 28301 FAX [phone]
NorthCarolina
naturally
An Equal Opportunity/Affirmative Action Employer- 50% Recyclec!M% Post Consumer Paper

Mr. Phillips
April 26, 2010
Page
Required Corrective Action for Deficiency 1:
DWQ has received a copy of your 30 Day Plan of Action (POA) for the high freeboard occurrence.
Take all necessary additional steps to insure lagoon levels remain in compliance with Section 2 of your
permit -
You are required to take any necessary action to correct the above deficiency and to provide a
written response to this Notice within 30 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.
If you have any questions concerning this notice.. please contact me at (910)-433-3300.
Sincerely,
Steve Guyton
Environmental Specialist
Fayetteville Regional Office
cc: Keith Larick CAFO Unit
Bladen County Soil and Water Conservation District
NCDSWC-FRO
FRO Compliance Animal Files
Murphy Brown Farms

W A rF9
]Michael F. Easley, Govemor
'4Z\OF
p
G
William G. Ross Jr., secretary
_Q
co
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
September 14, 2005
CERTIFIED MAIL
_RETURN RECEIPT REQUESTED
RECEIPT # 7002 2410 0003 0272 8705
Mr. Ray Reason
PO Box 2201
Elizabethtown, NC 28337
SUBJECT: Final Notice
Request for Payment of Civil Penalty
Farm # 9-16
Bladen County
File No. PC 04-013
Dear Mr. Reason:
REC V ET
SEP 16 a5
-'? :! t ILEREGIC OFnCE
Your immediate attention to this matter is required. On January 28, 2005, the Division of
Water Quality (DWQ) assessed a civil penalty against you in the amount of $4,621.14; including
$621.14 in investigative costs, for violations of your NPDES Permit.
On June 3, 2005, you agreed to a payment schedule of twelve (12) payments beginning on
August 1, 2005. There are eleven (11) payments of three hundred eighty-five dollars and ten
cents ($385.10) beginning on August 1, 2005 and one final payment of three hundred eighty-five
dollars and four cents ($385.04). As of September 14, 2005, no payment has been received.
This letter serves as final notice that DWQ will refer your case to the North
Carolina Attorney General's Office unless payment is received within 10 days of your
receipt of this notice. If necessary, the Attorney General's Office will file a case alzainst you
in the Superior Court of Bladen County to collect the penalty.
Please send the payment within ten calendar days to:
Mr. Keith Larick
DWQ
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
t=,rljor
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636
Intemet: htta://h2o.enr.state.nc.us 2728 Capital Boulevard Raleigh, NC 27604
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/100/6 Post Consumer Paper
Phone [phone] Customer service
Fax [phone]
Fax [phone]

Ray Reason
Page 2
September 14, 2005
Please sign the attached payment schedule and send it back with your first payment. Make a
copy of the payment schedule for your records. Please make the payments by check payable to
the Department of Environment and Natural Resources and mail them so they are received by the
1 st of each month.
t . .
If you would like a receipt that your payment was received, please send it via certified mail. If
you have any questions, please contact me at [phone] or Paul Sherman at (919) 715-
6697.
Sincerely,
Keith Larick
Animal Feeding Operations Unit
cc: Art Barnhardt, Fayetteville Regional Office
File # PC 04-013
APS Central Files

March 31, 2006
Mr. Ray Reason
PO Box 2201
Elizabethtown, NC 28337
RE: Acknowledgment of Receipt of Payment
Case DV 04-013
Farm # 09-16
Bladen County
Dear Mr. Reason:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
REUF EV
APR 0 4 20M
am-FAYEMaFBEGtOMtflF IL'E
This letter is to acknowledge receipt of your check No. 0847 in the amount of $385.10 on
March 29, 2006. The balance of the penalty is $2,310.54. r
Payment of this penalty does not preclude further action by this Division for violations of the
State's environmental laws. If you have any questions, please call me at [phone],
Sincerely,
d.aul Sherman, P.E.
Supervisor, Animal Feeding Operations Unit
cc: APS-Fayetteville Regional Office
Files # DV 04-013
APS Central Files
No Carolina
)1latura!!y
Aquifer Protection Section 1636 Mail Service Center
Internet: www.ncwaterqualiw.ora Location: 2728 Capital Boulevard
An Equal OpportunitylAffirmarWe Action Employer— 50% Retycledlt0% Post Consumer Paper
Raleigh. NC 27699-1636 Telephone: [phone]
Ralcigh, NC 27604 Fax 1: [phone]
Fax 2: [phone]
Customer Service: [phone]

Michael F. Easley, Governor
William G. Ross Jr., Secsdmy
North Carolina DepartmeA of Environment and Natural Resourm
June 3, 2005
CERTIFIED MAIL,
RETURN RECEIPT REQUESTED
Mr. Ray Reason
PO Box 2201
Elizabethtown, NC 28337
RE: Payment Schedule for Civil Penalty
Case PC 04-013
Farm # 9-16
Bladen County
Dear Mr. Reason:
Alm W. Klimek, P.E. Director
Division of Water Quality
RECEIVED
JUN - 6 20O5
OENR - FAYEMLLE REGIONAL OFFICE
You have requested a schedule for making partial payments toward the $4,621.14 civil
penalty that was assessed by the Division of Water Quality on January 28, 2005. The Division is
agreeable to a twelve (12) month payment schedule beginning on August 1, 2005 and continuing
to July 1, 2005_ There are eleven (11) payments of three hundred eighty-five dollars and ten
cents ($385.10) beginning on August 1, 2005 and one final payment of three hundred eighty-five
dollars and four cents ($385.04).
Please sign the attached payment schedule and send it back with your first payment. Make a
copy of the payment schedule for your records. Please make the payments by check payable to
the D artment of Environment and Natural Resources and mail them so they are received by the
1 st of each month.
Failure to make the monthly payments in accordance with this schedule will cause the
entire unpaid balance of the civil penalty to be due and payable and subject to collection
through a civil action in the superior court.
Mail your payments to the address shown below to make sure that they are properly
recorded.
Mr. Steve Lewis
DWQ
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
ON
E
Aquifer Protection Section 1636 Maul Service Centeir Raleigh, NC 27699-1636 Phone [phone] Customer service
Internet: hqyJlh2o.enr.9ate= us 2729 Capital Boulevard Raleigh, NC 27604 Fax [phone]-M-623-6748

Mr. Ray Reason
June 3, 2005
Page 2
If you have any questions, please call Mr. Steve Lewis at [phone] or Keith Larick at
[phone].
Sincerely,
Alan W. Klimek, P.E.
Director, Division of Water Quality
cc: Art Barnhardt, Fayetteville Regional Supervisor w/o attachment
mmylRaTley FRO w/o attachment
File PC-04-013 w/ attachment
APS Central Files w/o attachment

VAR
Q
Y
Michael F. Easley, Governor
William G. Ross Jr, Secretary
Borth Carolina Departmem of Fnvirosm=4 and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
June 3, 2005
CERTIFIED MAIL ��D����D
RETURN RECEIPT REQUESTED
Mr. Ray Reason
PO Box 2201
Elizabethtown, NC 28337
RE: Payment Schedule for Civil Penalty
Case PC 04-013
Farm # 9-16
Bladen County
Dear Mr. Reason:
JUN - 6 2005
DENR-FAYFiiE ILEREGfONALOFflCE
You have requested a schedule for ]Waking partial payments toward the $4,621.14 civil
penalty that was assessed by the Division of Water Quality on January 28, 2005. The Division is
agreeable to a twelve (12) month payment schedule beginning on August 1, 2005 and continuing
to July 1, 2005. There are eleven (11) payments of three hundred eighty-five dollars and ten
cents ($385.10) beginning on August 1, 2005 and one final payment of three hundred eighty-five
dollars and four cents ($385.04).
Please sign the attached payment schedule and send it back with your first payment. Make a
copy of the payment schedule for your records. Please make the payments by check payable to
the Department of Environment and Natural Resources and mail them so they are received by the
1 st of each month.
Failure to make the monthly payments in accordance with this schedule will cause the
entire unpaid balance of the civil penalty to be due and payable and subject to collection
through a civil action in the superior court.
Mail your payments to the address shown below to make sure that they are property
recorded.
Mr. Steve Lewis
DWQ
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
Aquifer Protection Section 1636 Mail Service Caner Raleigh, NC 27699-1636 Pbono [phone] Custa®a service
lydernet: httO/h2o_em.Aatcmc.us 2728 Capital Boulevard Raleigh, NC 27604 Fax [phone]U 1-877-623-6748

I,� .Ray Reason
June 3, 2005
Page 2
1f you have any questions, please call Mr. Steve Lewis at [phone] or Keith Luick at
[phone].
Sincerely,
Alan W. Klimek, P.E.
Director, Division of Water Quality
cc: Artarnhard�Fayetteville Regional Supervisor w/o attachment
Larry Baxley, FRO w/o attachment
File PC-04-013 w/ attachment
APS Central Files w/o attachment

WZ\1FW A rF
`0G
7
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Reason
PO Box 2201
Elizabethtown, NC 28337
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Depanment of Environment and Natural Resources
January 28, 2005
SUBJECT: Assessment of Civil Penalties
for Violations of Permit Conditions
Farm # 9-16
Bladen County
File No. PC 04-013
Dear Mr. Reason:
Alan W. Klimek, P.E. Director
Division of Water Quality
RECEIVED
JAN11 3 1 200-3
DENR - FAY-EP-EVILLE REGIONAL QFRCE
This letter transmits notice of a civil penalty assessed against Reason Farms 1 & 2 in the amount
of $4,621.14 which includes $621.14 in investigative costs. Attached is a copy of the assessment
document explaining this penalty.
This action was taken under the authority vested in me by delegation provided by the Secretary
of the Department of Environment and Natural Resources and the Director of the Division of
Water Quality. Any continuing violation(s) may be the subject of a new enforcement action,
including an additional penalty.
Within thirty days of receipt of this notice, you must do one of the following three items:
1. Submit payment of the penalty:
Payment should be made to the order of the Department of Environment
and Natural Resources. Payment of the penalty will not foreclose further
enforcement action for any continuing or new violation(s). Do not include
the attached waiver form if making payment.
Please send payment to the attention of
Mr. Steve Lewis
DWQ
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
N� Carolina
�� 2NIZ
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
Internet: htty://h2o.enr.state.nc.us 2728 Capital Boulevard Raleigh, NC 27604 Fax [phone]
Fax [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/]0% Post Consumer Paper

q ,
2. Submit a written request for remission or mitigation including a
detailed justification for such request:
A request for remission or mitigation is limited to consideration of the reasonableness
of the amount of the penalty and is not the proper procedure for contesting the
accuracy of any of the statements contained in the assessment letter. Because a
remission request forecloses the option of an administrative hearing, such a request
must be accompanied by a waiver of your right to an administrative hearing and a
stipulation that there are no factual or legal issues in dispute. You must execute and
return to this office the attached waiver form and the attached "Justification for
Remission Request" which should describe why you believe:
(a) one or more of the civil penalty assessment factors in G.S. 143B-282.1(b)
were wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting from
the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Please submit this information to the attention of
Mr_ Steve Lewis
DWQ
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
i7
3. Submit a written request for an administrative hearing:
If you wish to contest any portion of the civil penalty assessment, you must request an
administrative hearing_ This request must be in the form of a written petition to the
Office of Administrative Hearings and must conform to Chapter 150B of the North
Carolina General Statutes. You must file your original petition with the:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714

AND
Mail or hand -deliver a copy of the petition to:
And to:
Mr_ Dan Oakley
NCDENR
Office of General Counsel
1601 Mail Service Center
Raleigh, NC 27699-1601
Mr. Steve Lewis
DWQ
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
Failure to exercise one of the options above within thirty days, as evidenced by a date stamp (not
a postmark) indicating when we received your response, will result in this matter being referred
to the Attorney General's Office with a request to initiate a civil action to collect the penalty.
Please be advised that additional assessments may be levied for future violations which occur
after the review period of this assessment.
If you have any questions, please contact Mr. Steve Lewis at [phone] or Mr. Keith Larick
at [phone].
Sincerel
heodore L. Bush, Jr., Chief
Aquifer Protection Section
TLB/scl
ATTACHMENTS
cc: BaIiardt, Fayetteville APS Regional Supervisor w/ attachments
Larry Baxley, FRO w/ attachments
File # PC 04-013 w/ attachments
APS Central Files w/ attachments
Susan Massengale, PIO w/ attachments

STATE OF NORTH CAROLINA
COUNTY OF _ BLADEN
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
ENVIRONMENTAL MANAGEMENT
COMMISSION
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
RAY REASON ) STIPULATION OF FACTS
FILE NO. PC 04-013
Having been assessed civil penalties totaling $4 621.14 for
violation(s) as set forth in the assessment document of the Director of the Division of Water Quality
dated January 28, 2005 , the undersigned, desiring to seek remission of the civil
penalties, does hereby waive the right to an administrative hearing in the above -stated matter and
does stipulate that the facts are as alleged in the assessment document.
The undersigned further understands that all evidence presented in support of remission of
this civil penalty must be submitted to the Director of the Division of Water Quality within thirty (30)
days of receipt of the civil penalty assessment. No new evidence in support of a remission request
will be allowed after thirty (30) days from the receipt of the civil penalty assessment.
This the day of , 20
SIGNATURE
ADDRESS
TELEPHONE

JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number: PC 04-013 County: Bladen
Assessed Party: Ray Reason
Permit No. (if applicable): NCA209016 Amount Assessed: $4,621.14
Please use this form when'requesting remission of this civil penalty. You must also complete the
"Request For Remission, Waiver of Right to an Administrative Hearings and Stipulation of
Facts" form to request remission of this civil penalty. You should attach any documents that
you believe support your request and are necessary for the Director to consider in evaluating
your request for remission. Please be aware that a request for remission is limited to
consideration of the five factors listed below as they may relate to the reasonableness of the
amount of the civil penalty assessed. Requesting remission is not the proper procedure for
contesting whether the violation(s) occurred or the accuracy of any of the factual statements
contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c),
remission of a civil penalty may be granted only when one or more of the following five factors
applies. Please check each factor that you believe applies to your case and provide a detailed
explanation, including copies of supporting documents, as to why the factor applies (attach
additional pages as needed).
(a) one or more of the civil poAlly assessment factors in N.C.G.S. 143B-282.1
were wrongfully applied to the detriment of the petitioner (the assessment factors are listed in
the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the
violation (i.e., explain the steps that you took to correct the violation and prevent future
occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the
violation was unavoidable or something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) pMent of the civil penalty will prevent payment for the remaining necess
remedial actions (i.e., explain how payment of the civil penalty will prevent you from performing
the activities necessary to achieve compliance).
EXPLANATION (attach additional pages as necessary):

STATE OF NORTH CAROLINA NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
COUNTY OF BLADEN
File No. PC 04-013
IN THE MATTER OF
RAY REASON
FOR NPDES GENERAL ) FINDINGS AND DECISION
PERMIT VIOLATIONS ) AND ASSESSMENT OF
} CIVIL PENALTIES
Acting pursuant to delegation provided by the Secretary of the Department of
Environment and Natural Resources and the Director of the Division of Water Quality, I,
Theodore L. Bush, Jr., Chief of the Aquifer Protection Section of the Division of Water Quality
(DWQ), make the following:
I. FINDINGS OF FACT:
A. Ray Reason owns and operates Reason Farms 1 & 2, a swine operation in Bladen
County.
B. Ray Reason was issued Certificate of Coverage NCA209016 under NPDES
General Permit NCA200000 for Reason Farms 1 & 2 on April 9, 2003, effective
April 9, 2003, with an expiration date of July 1, 2007.
C. Condition No. V. 3. of the General Permit states in part "The maximum waste
level in lagoons/storage ponds 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 ...". CAWMP
is the acronym for Certified Animal Waste Management Plan.
D. Based on the 25-year, 24-hour storm event of seven (7) inches and one foot of
required structural freeboard, the waste Ievel in the lagoons for Reason Farms I &
2 shall not exceed nineteen (19) inches.
E. DWQ staff from the Fayetteville Regional Office inspected Reason Farms I & 2
on September 9, 2004 and observed that the waste level for the lagoon identified
as #2 was sixteen (16) inches, which exceeded the level specified in the CAWMP.

I
F. Condition No. 111. 11. e. of the General Permit requires that the permittee shall
report by telephone to the appropriate Regional Office as soon as possible, but in
no case more than 24 hours following first knowledge of the occurrence of failure
to maintain storage capacity in a lagoon/storage pond greater than or equal to that
required in Condition V.3 of the issued permit.
G. The Fayetteville Regional Office did not receive notification from Ray Reason or
his representative(s) that the waste level in Iagoon #2 exceeding that specified in
the CAWMP.
H. Condition No. Ill. 19. of the General Permit states in part "Within five (5)
working days of receiving the request from the Division, the Permittee shall
provide to the Division one (1) copy of all requested information and reports
related to the operation of the animal waste management system."
1. In a Notice of Violation (NOV) dated September 16, 2004, the Fayetteville
Regional Office requested copies of all lagoon levels and rainfall records for the
farm from January 1, 2004 to present and a copy of the current copy of the
facility's CAWMP. DWQ has the certified mail green card showing that the
NOV was received on September 20, 2004.
J. In an NOV dated October 12, 2004, the Fayetteville Regional Office requested
that the facility submit a Plan of Action within forty-eight (48) hours indicating
how the facility proposed to lower the lagoon level to greater than nineteen (19)
inches within thirty (30) days. The regional office also requested weekly update
reports until the waste lagoon level reaches compliance and a written explanation
of how the facility will maintain waste lagoon level compliance throughout the
fall growing season. The DWQ has the certified mail green card showing the
NOV was received on October 13, 2004.
K. To date, the Fayetteville Regional Office has not received the information
requested in either the NOV dated September 16, 2004 or the NOV dated October
12, 2004.
L. The costs to the State of the enforcement procedures in this matter totaled
$621.14.
Based upon the above Findings of Fact, I make the following:
U CONCLUSIONS OF LAW.
A. Ray Reason is a "person" within the meaning of G.S. 143-215.6A pursuant to G.S.
143-212(4).
B. A permit for an animal waste management system is required by G.S. 143-215.1.

$ 9 0 01 0 0 for 2 of two violations for violating Condition No.
111. 19. of the General Permit by failing to provide
information requested in the Notices of Violation dated
September 16, 2004 and October 12, 2004.
$ 41 Q 01242c> TOTAL CIVIL PENALTY
$ 62 t -14 Enforcement costs
TOTAL AMOUNT DUE
As required by G.S. 143-215.6A(c), in determining the amount of the penalty I considered
the factors listed in G.S. 14313-282. 1 (b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
and
(8) The cost to the State of the enforcement procedures.
(Date)
Aquifer Protection Section
Division of Water Quality

F W Ar,7
Michael F. Easley, Governor
owl i
William G. Ross Jr., Secretary
C�r
North Carolina Department of Environment and Natural Resources
.1c
Alan W. Klimek, P.E. Director
Division of Water Quality
January 28, 2005
CERTIFIED MAIL
RETURN RECEIPT_ REQUESTED
Mr. Ray Reason
PO Box 2201
Elizabethtown, NC 28337
SUBJECT: Assessment of Civil Penalties
for Violations of Permit Conditions
Faun # 9-16
Bladen County
File No. PC 04-013
Dear Mr. Reason:
RECEIVE®
JAB! 3 1 2005
DENR-FAYETTEVILLE REGIONALOFRCE
This letter transmits notice of a civil penalty assessed against Reason Farms 1 & 2 in the amount
of $4,621.14 which includes $621.14 in investigative costs. Attached is a copy of the assessment
document explaining this penalty.
This action was taken under the authority vested in me by delegation provided by the Secretary
of the Department of Environment and Natural Resources and the Director of the Division of
Water Quality. Any continuing violation(s) may be the subject of a new enforcement action,
including an additional penalty.
Within thirty days of receipt of this notice, you must do one of the following three items:
1. Submit payment of the penalty:
Payment should be made to the order of the Department of Environment
and Natural Resources. Payment of the penalty will not foreclose further
enforcement action for any continuing or new violation(s). Do not include
the attached waiver form if making payment.
Please send payment to the attention of:
Mr. Steve Lewis
DWQ
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
NoEhCarolina
Aaturally
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
Internet: http://h2o.enr.state.ne-us 2728 Capital Boulevard Raleigh, NC 27604 Fax [phone]
Fax [phone]
An Equal opportunity/Affirmative Action Employer — 50% Recycled/] 0% Post Consumer Paper

iV
2. Submit a written request for remission or mitigation including a
detailed justification for such request:
A request for remission or mitigation is limited to consideration of the reasonableness
of the amount of the penalty and is not the proper procedure for contesting the
accuracy of any of the statements contained in the assessment letter. Because a
remission request forecloses the option of an administrative hearing, such a request
must be accompanied by a waiver of your right to an administrative hearing and a
stipulation that there are no factual or legal issues in dispute. You must execute and
return to this office the attached waiver form and the attached "Justification for
Remission Request" which should describe why you believe:
(a) one or more of the civil penalty assessment factors in G.S. 143B-282.1(b)
were wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting from
the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Please submit this information to the attention of:
Mr. Steve Lewis
DWQ
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
No
3. Submit a written request for an administrative hearing:
If you wish to contest any portion of the civil penalty assessment, you must request an
administrative hearing. This request must be in the form of a written petition to the
Office of Administrative Hearings and must conform to Chapter 150B of the North
Carolina General Statutes. You must file your original petition with the:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714

AND
Mail or hand -deliver a copy of the petition to:
And to:
Mr. Dan Oakley
NCDENR
Office of General Counsel
1601 Mail Service Center
Raleigh, NC 27699-1601
Mr. Steve Lewis
DWQ
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
Failure to exercise one of the options above within thirty days, as evidenced by a date stamp (not
a postmark) indicating when we received your response, will result in this matter being referred
to the Attorney General's Office with a request to initiate a civil action to collect the penalty.
Please be advised that additional assessments may be levied for future violations which occur
after the review period of this assessment.
If you have any questions, please contact Mr. Steve Lewis at [phone] or Mr. Keith Larick
at [phone].
Sincere(
heodore L. Bush, Jr., Chief
Aquifer Protection Section
TLB/sc
ATTACHMENTS
cc: Art Barnhardt, Fayetteville APS Regional Supervisor w/ attachments
Ca"riyBaxiey;,FRO w/ attachments
File # PC 04-013 w/ attachments
APS Central Files w/ attachments
Susan Massengale, PIO w/ attachments

STATE OF NORTH CAROLINA ENVIRONMENTAL MANAGEMENT
COMMISSION
COUNTY OF BLADEN
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST } ADMINISTRATIVE HEARING AND
RAY REASON } STIPULATION OF FACTS
FILE NO. PC 04-013
Having been assessed civil penalties totaling $4,621.14 for
violation(s) as set forth in the assessment document of the Director of the Division of Water Quality
dated _ January 28, 2005 _, the undersigned, desiring to seek remission of the civil
penalties, does hereby waive the right to an administrative hearing in the above -stated matter and
does stipulate that the facts are as alleged in the assessment document.
The undersigned further understands that all evidence presented in support of remission of
this civil penalty must be submitted to the Director of the Division of Water Quality within thirty (30)
days of receipt of the civil penalty assessment. No new evidence in support of a remission request
will be allowed after thirty (30) days from the receipt of the civil penalty assessment.
This the day of
ADDRESS
TELEPHONE
SIGNATURE

JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number: PC 04-013 County: Bladen
Assessed Party: Ray Reason
Permit No. (if applicable): NCA209016 Amount Assessed: S4,621.14
Please use this form wheri requesting remission of this civil penalty. You must also complete the
"Request For Remission. Waiver of Right to an Administrative Hearing, and Stipulation of
Facts" form to request remission of this civil penalty. You should attach any documents that
you believe support your request and are necessary for the Director to consider in evaluating
your request for remission. Please be aware that a request for remission is limited to
consideration of the five factors listed below as they may relate to the reasonableness of the
amount of the civil penalty assessed. Requesting remission is not the proper procedure for
contesting whether the violation(s) occurred or the accuracy of any of the factual statements
contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c),
remission of a civil penalty may be granted only when one or more of the following five factors
applies. Please check each factor that you believe applies to your case and provide a detailed
explanation, including copies of supporting documents, as to why the factor applies (attach
additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b)
were wrongfully applied to the detriment of the petitioner (the assessment factors are listed in
the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting, from the
violation (i.e., explain the steps that you took to correct the violation and prevent future
occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the
violation was unavoidable or something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil enal will prevent payment for the remaining necess
remedial actions (i. e., explain how payment of the civil penalty will prevent you from performing
the activities necessary to achieve compliance).
EXPLANATION attach additional vages as necess

STATE OF NORTH CAROLINA
COUNTY OF BLADEN
IN.THE MATTER OF
RAY REASON
FOR NPDES GENERAL
PERMIT VIOLATIONS
NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
File No. PC 04-013
FINDINGS AND DECISION
AND ASSESSMENT OF
CIVIL PENALTIES
Acting pursuant to delegation provided by the Secretary of the Department of
Environment and Natural Resources and the Director of the Division of Water Quality, 1,
Theodore L. Bush, Jr., Chief of the Aquifer Protection Section of the Division of Water Quality
(DWQ), make the following:
I. FINDINGS OF FACT:
A. Ray Reason owns and operates Reason Farms 1 & 2, a swine operation in Bladen
County.
B. Ray Reason was issued Certificate of Coverage NCA209016 under NPDES
General Permit NCA200000 for Reason Farms l & 2 on April 9, 2003, effective
April 9, 2003, with an expiration date of July 1, 2007.
C. Condition No. V. 3. of the General Permit states in part "The maximum waste
level in lagoons/storage ponds 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 ...". CAWMP
is the acronym for Certified Animal Waste Management Plan.
D. Based on the 25-year, 24-hour storm event of seven (7) inches and one foot of
required structural freeboard, the waste level in the Lagoons for Reason Farms I &
2 shall not exceed nineteen (19) inches.
E. DWQ staff from the Fayetteville Regional Office inspected Reason Farms 1 & 2
on September 9, 2004 and observed that the waste level for the lagoon identified
as 42 was sixteen (I6) inches, which exceeded the level specified in the CAWMP.

F. Condition No. III. 11. e. of the General Permit requires that the pennittee shall
report by telephone to the appropriate Regional Office as soon as possible, but in
no case more than 24 hours following first knowledge of the occurrence of failure
to maintain storage capacity in a lagoon/storage pond greater than or equal to that
required in Condition V.3 of the issued permit.
G. The Fayetteville Regional Office did not receive notification from Ray Reason or
his representative(s) that the waste level in lagoon #2 exceeding that specified in
the CAWMP. --- _-- - —
H. Condition No. III. 19. of the General Permit states in part "Within five (5)
working days of receiving the request from the Division, the Permittee shall
provide to the Division one (1) copy of all requested information and reports
related to the operation of the animal waste management system."
I. In a Notice of Violation (NOV) dated September 16, 2004, the Fayetteville
Regional Office requested copies of all lagoon levels and rainfall records for the
farm from January 1, 2004 to present and a copy of the current copy of the
facility's CAWMP. DWQ has the certified mail green card showing that the
NOV was received on September 20, 2004.
J. In an NOV dated October 12, 2004, the Fayetteville Regional Office requested
that the facility submit a Plan of Action within forty-eight (48) hours indicating
how the facility proposed to lower the lagoon level to greater than nineteen (19)
inches within thirty (30) days. The regional office also requested weekly update
reports until the waste lagoon level reaches compliance and a written explanation
of how the facility will maintain waste lagoon level compliance throughout the
fall growing season. The DWQ has the certified mail green card showing the
NOV was received on October 13, 2004.
K. To date, the Fayetteville Regional Office has not received the information
requested in either the NOV dated September 16, 2004 or the NOV dated October
12, 2004.
L. The costs to the State of the enforcement procedures in this matter totaled
$621.14,
Based upon the above Findings of Fact, I make the following:
11. CONCLUSIONS OF LAW:
A. Ray Reason is a "person" within the meaning of G.S. 143-215.6A pursuant to G.S.
143-212(4).
B. A permit for an animal waste management system is required by G.S. 143-215.1.

C. The above -cited failure to maintain the liquid level in the lagoon at the level
specified in the CAWMP violated Condition No. V. 3. of the NPDES General
Permit.
D. The above -cited failure to report by telephone to the appropriate Regional Office
as soon as possible, but in no case more than 24 hours following first knowledge
of the occurrence of failure to maintain storage capacity in a lagoon/storage pond
greater than or equal to that required in Condition No. V. 3 violated Condition No.
III. 11. e. of the NPDES-General Permit.
E. The above -cited failure to provide the information requested in the Notices of
Violation dated September 16, 2004 and October 12, 2004 violated Condition No.
III. 19, of the General Permit.
F. Ray Reason may be assessed civil penalties pursuant to G.S. 143-215.6A(a)(2)
which provides that a civil penalty of not more than twenty-five thousand dollars
($25,000.00) per violation may be assessed against a person who violates or fails
to act in accordance with the terms, conditions, or requirements of a permit
required by G.S. 143-215.1.
G. The State's enforcement costs in this matter may be assessed against Ray Reason
pursuant to G.S. 143-215.3(a)(9) and G.S. 143B-282.1(b)(8).
H. The Chief of the Aquifer Protection Section, Division of Water Quality, pursuant
to delegation provided by the Secretary of the Department of Environment and
Natural Resources and the Director of the Division of Water Quality, has the
authority to assess civil penalties in this matter.
Based upon the above Findings of Fact and Conclusions of Law, I make the following:
III. DECISION,
Ray Reason is hereby assessed a civil penalty of:
$ 1, D D 0) 0 0 for violating Condition No. V. 3- of the General Permit by
failing to maintain the liquid level in the lagoon at the level
specified in the CAWMP
$ 1 . D 0, D e for violating Condition No. IIl. 11. e. of the General Permit
by failing to report by telephone to the appropriate Regional
Office as soon as possible, but in no case more than 24
hours following first knowledge of the occurrence of failure
to maintain storage capacity in a lagoon/storage pond
greater than or equal to that required in Condition No. V.3.

i
t) 0 for _ 2 of two violations for violating Condition No.
III. 19. of the General Permit by failing to provide
information requested in the Notices of Violation dated
September 16, 2004 and October 12, 2004.
$ 4 o p TOTAL CIVIL PENALTY
$ 621 14 Enforcement costs
$ jp _ TOTAL AMOUNT DUE
As required by G.S. 143-215.6A(c), in determining the amount of the penalty I considered
the factors listed in G.S. 143B-282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
and
(8) The cost to the State of the enforcement procedures.
(Date)
T dare L. Bush, Jr_, Chief
Aquifer Protection Section
Division of Water Quality

O�o� W A 7'�RpG
o
woe � e �e�ea45
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Michael F. Easley, Governor
William G. Ross Jr.. Secretary
North Carolina Department of Environment and Natural Resources
Lis
6T. Alan W. Klimek, P.E. Director
".Aw G - , l Division of Water Quality
C d I vv0r- Sir
'
� % StJ C�7'✓�'�r
'Ie
ray
ANO Af
4rf
Mr. Ray Reason
PO 2201
Elizabethtown, North Carolina 28337
Subject: NOTICE OF VIOLATIONINOTICE OF INTENT
North Carolina General Statutes 143 - 215
Reason Farms #1 & # 2
Facility No. 9 - 16
Bladen County
Dear Mr. Reason:
You are hereby notified that, having been permitted to have non-dis a permit for the subject animal waste
disposal system pursuant to NCGS 143 - 215, you have been ound to be in violation of your NPDES Permit.
Violation 1: Failure to maintain adequate records as required by your NPDES Permit. (Permit No.
NCA290016 Section 3 condition 10 of the facility's NPDES Permit.)
This violation is in reference to Reason Farms having only one documented analyzed waste sample during the
2004 crop cycle at the time of inspection. Permit conditions requiring records of crop yield information must be
followed_ The documentation of the annual irrigation equipment calibration had not been completed. The use of
l approved forms to record waste treatment inspections both monthly and after onr greater storm events was
inadequate. Further the Certificate of Coverage and a copy of the Permit were not in the farm records at the time of
inspection.
Required Corrective Action for Violation 1:
Please maintain COC and a copy of your Permit with the farm records. Also immediately begin to follow all
conditions of your permit and CAWMP. This includes all documentation and recordkeeping for compliance with your
NPDES Permit and your CAWMP_
Violation 2: Failure to follow the CAWMP.
The inspection conducted on 12/21/04 documented continued noncompliance with the CAWMP and Permit
procedures as sited in the NOVINOI of October 12,2004. During the 2004 crop cycle soybeans were planted as a
receiving crop and they were not part of the CAWMP for this farm at that time. Later an amendment was added but
not in the allotted time frame.
The Bermuda fields had not been overseeded as of 12/21/04 and in many areas the Bermuda stand is not
adequate as a receiving crop.
NorthCarolina
Naturally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirmative Action Employer - 501/6 Recycled110% Post Consumer Paper

3. The facility's COC and its CAWMP are hereby incorporated by reference into this
permit. The CAWMP must be consistent with all applicable laws, rules, ordinances, and
standards (federal,state and local) in effect at the time of siting, design and certification of
the facility. The Permittee must assess, on an ongoing basis, the effectiveness of the
implementation of the CAWMP. The Permittee must amend the CAWMP in order to
address any changes needed to maintain compliance with the facility's COC and this
permit. Any amendment to the CAWMP must be documented, dated, and included as part
of the CAWMP. All amendments, along with an explanation identifying all amendments,
shall be submitted to the appropriate Division regional office within ten (10) working
days of the amendment. If field, riser or pull numbers are changed as a result of the
amendment, an explanation shall also be submitted and include a description of how the
new numbers relate to the old numbers.
Any violation of the COC or the CAWMP 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 or
the Environmental Protection Agency (EPA). These actions may include but are not
limited to: modifying the CAWMP; ceasing land application of waste; removing animals
from the facility; or the COC being reopened and modified, revoked and reissued, and/or
terminated.

r
Mr. Reason SAuVA41 3� lovs
Deeeffibef-29, 2004
Page 2
ft+tt�+°�tfy staff from the Fayetteville Regional Office conducted a Compliance Inspection at facility 9 — 16 and on
that date the lagoon levels were lagoon # 1 at 18" and lagoon # 2 at 19.5". It was brought to your attention at that
time that no notification had been received and a 30 day Plan of Action should be submitted within 48 hours for
lagoon # 1. As of 12/29/04 no Plan of Action has been received_
Previously on 919104 a lagoon level was documented at 16" in lagoon # 2 and a Notice of Violation/Notice of
Intent was sent certified mail to you_ The NOVINOI dated October 12, 2004 was signed for by a Ms. Becky Warren
on the 130' of October 2004.This document specified that a Plan of Action must be submitted within 48 hours to the
Fayetteville Regional Office. It also specified other requested information and expectations of your facility to
achieve compliance. No response was received by this office. A copy of this document is included with this
mailing. Failure to respond is an enforceable permit violation. The expectations of that October 12, 2004 NOVINOI
are still required for your farm to comply. They are.-
-Within 60 days of receipt of this notice please obtain and submit a comprehensive review report of your CAWMP
by a Technical Specialist. The purpose of this review is to identify the cause(s) of the facility not being able to
maintain adequate freeboard in it's structures and must contain corrective action taken or proposed to improve the
facility's compliance.
-Submit weekly update reports by 11:00 AM each Monday indicating, (1) the structure liquid level(s) and (2) total
volume of waste irrigated or removed from the system for the seven days prior to the report date. Transfers
between the two lagoons should be included. These weekly updates should continue until all structures are greater
than 19 inches.
-Provide a detailed written explanation of how the farm will gain and maintain compliance of its lagoon levels,
CAWMP and Permit in the year 2005.
Violation 3: Failure to notify the Division of Water Quality of inadequate freeboard in a waste structure(s)
within 24 hours. (Permit No. NCA290016 Section III Condition 11e)
Your permit specially 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. The Division of Water Quality has no
record of receiving the 24- hour notification or the 5-day written report.
Required Corrective Action:
In the future, please notify the Division of Water Quality of the occurrence of any reportable events in accordance
with your permit
Violation 4: Failure to maintain waste levels in your waste structure(s) in accordance with the facilities
Certified Animal waste Management Plan. (Permit No. NCA290016 Section V Condition 3).
On 12/21/04 a lagoon/storage pond level was documented at 18 inches of freeboard at Reason Farm #1 lagoon. A
level of 19 inches is the maximum level allowed by your permit.
Please be advised that this notice does not prevent the Division of Water Quality from taking enforcement actions
for these violation or any past or future violation. Furthermore, the Division of Water Quality has the authority to
levy a civil penalty of not more than $25,000.00 per day per violation.

Mr. Ray Reason
—VQ9fe4--�--,or-Jnr j 3,11M5
Page 3
It is the opinion of this office that the events surrounding your farm and the history of noncompliance that it
continues to build demonstrates poor operation and management. This trend is not in the best interest of any of the
parties associated with Reason Farms #1 & #2 and requires a new commitment to following all aspects of the
Permit and CAWMP that are within the Permittees control. This office will assist in any manner possible but all
responsibilities for permit compliance are the permittees_ This office will conduct more frequent inspections at the
facility during the 2005-year and it is the expectation that Mr_ Reason will be present at those inspections to discuss
the condition of the farm at that time.
If you have any questions concerning this matter, please do not hesitate to contact Mr. Larry C. Baxley,
Environmental Specialist, or myself at [phone].
Sincerely,
Stephen A. Barnhardt
Regional Aquifer Protection Supervisor
cc: Keith Larick - Compliance Group
Chris Bordeaux - Bladen Co. NRCS
Trent Allen — SWC, FRO
Central Files - Raleigh

Michael F. Easley, Governor
William G. Ross IT., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
December 29, 2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Reason
PO 2201
Elizabethtown, North Carolina 28337
Subject: NOTICE OF VIOLATION/NOTICE OF INTENT
North Carolina General Statutes 143 - 215
Reason Farms #1 & # 2
Facility No. 9 - 16
Bladen County
Dear Mr. Reason:
You are hereby notified that, having been permitted to have a non -discharge permit for the subject animal waste
disposal system pursuant to NCGS 143 - 215, you have been found to be in violation of your NPDES Permit_
Violation 1: Failure to maintain adequate records as required by your NPDES Permit. (Permit No.
NCA290016 Section 3 condition 10 of the facility's NPDES Permit)
This violation is in reference to Reason Farms having only one documented analyzed waste sample during the
2004 crop cycle at the time of inspection. Permit conditions requiring records of crop yield information must be
followed. The documentation of the annual irrigation equipment calibration had not been completed. The use of
approved forms to record waste treatment inspections both monthly and after one or greater storm events was
inadequate. Further the Certificate of Coverage and a copy of the Permit were not in the farm records at the time of
inspection_
Required Corrective Ac " for Violation 1: fie /l en v�
Please maintain CO and a copy of yoprVermit with the farm records. Also immediately begin to follow all
conditions of your permit and CAWMP. This includes all documentation and recordkeeping for compliance with your
NPDES Permit and your CAWMP.
Violation 2: Failure to follow the CAWMP.
The inspection conducted on 12/21/04 documented continued noncompliance with the CAWMP and Permit
procedures as sited in the NOV/NOI of October 12,2004. During the 2004 crop cycle soybeans were planted as a
receiving crop and they were not part of the CAWMP for this farm at that time. Later an amendment was added but
not in the allotted time frame.
The Bermuda fields had not been overseeded as of 12/21/04 and in many areas the Bermuda stand is not
adequate as a receiving crop.
{ r cam, tt S �_o 13e" 0+.- Oda- a
_S /- 7 No'hCarolina
Nalmrmlly
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal OpportunitylAffirmative Action Employer — 509% Recycledl1096 Post Consumer Paper

.l
Ole_
9/�/01 /4"
?
Mr_ Reason
December 29, 2004
Page 2
Recently staff from the Fa tteville Regional Office cond/cted a Compliance Ins ection at facility 9 — 16 and on
that date the lagoon levels ere lagoon # 1 at 18" and lagoon # 2 at 19.5". It w brought to your attention at that
time that no notification h been received and 30 day Plan of Action shout a submitted within 48 hours for
lagoon # 1. As of 12129/0 no Plan of Action hA been received.
Previously on 9/9/04 a goon level was documented at 16" in lagoon # 2 nd a Notice of Violation/Notice of
Intent was sent certified ail to you. The NOV/NOI dated October 12, 2004 was signed for by a Ms. Becky Warren
on the 13t' of October 2 04.This document specified that a Plan of Action must be submitted within 48 hours to the
Fayetteville Regional ice. It also specified other requested information and expectations of your facility to
achieve compliance. No response was received by this office. A copy of this document is included with this
mailing. Failure to respond is an enforceable permit violation_ The expectations of that October 12, 2004 NOV/NOI
are still required for your farm to comply. They are:
-Within 60 days of receipt of this notice please obtain and submit a comprehensive review report of your CAWMP
by a Technical Specialist. The purpose o biszeview is to identify the cause(s) of the facility not being able to
maintain adequate freeboard s and must contain corrective actiov�aken or p posed to improve the
facility's compliance.
-Submit weekly update reports by 11-00 AM each Monday indicating, (1) the structure liquid levef(s) and (2) total
volume of waste irrigated or removed from the system for the seven days prior to the report date_ Transfers
between the two lagoons should be included. These weekly updates should continue until all structures are greater
than 19 inches.
-Provide a detailed written explanation of how the farm will gain and maintain compliance of its lagoon levels,
CAWMP and Permit in the year 2005.
Violation 3: Failure to notify the Division of Water Quality of inadequate freeboard in a waste structure(s)
within 24 hours. (Permit No. NCA290016 Section III Condition 11e)
Your permit specially requires notification by telephone within 24 hours and a written report within 5 calendar days
v following first knowledge of the occurrence of a reportable permit condition. The Division of Water Quality has no
record of receiving the 24- hour notification or the 5-day written report.
Required Corrective Action:
In the future, please notify the Division of Water Quality of the occurrence of any reportable events in accordance
with it your opermit / &4 Ck r ' a
y 1 p � t_Y+ J�l.� QC PtG..1 r � �:�/`a/J t ir Q f`!
f f� u l p r v`
L �i`
Violation 4: Failure to maintain waste levels in your waste structure(s) in accordance with the facilities
Certified Animal waste Management Plan. (Permit No. NCA290016 Section V Condition 3).
On 12/21/04 a lagoontstorage pond level was documented at 18 inches of freeboard at Reason Farm #1 lagoon. A
level of 19 inches is the maximum level allowed by your permit.
Please be advised that this notice does not prevent the Division of Water Quality from taking enforcement actions
for these violation or any past or future violation. Furthermore, the Division of Water Quality has the authority to
levy a civil penalty of not more than $25,000.00 per day per violation.

t I'
Mr. Ray Reason
12/29/04 P
Page 3 ®f Q
It is the opinion of this office that the events surrounding your arm and the history of noncompliance that it
continues to build demonstrates poor operation and manage ent_ This trend is not in the best interest of any of the
parties associated with Reason Farms #1 & #2 and requires a new commitment to following all aspects of the
Permit and CAWMP that are within the Permittees control. is office will assist in any manner possible but all
responsibilities for permit compliance are the permittees. T is office will conduct more frequent inspections at the
facility during the 2005-year and it is the expectation that r. Reason will be present at those inspections to discuss
the condition of the farm at that time_
•
If you have any questions concerning this matter, please do not hesitate to contact Mr.'Larry C_ Baxley,
Environmental Specialist, or myself at [phone] _
Sincerely,
Stephen A. Barnhardt
Regional Aquifer Protection Supervisor
cc: Keith Larick - Compliance Group
Chris Bordeaux - Bladen Co. NRCS
Trent Allen -- SWC, FRO
Central Files - Raleigh

- O�0� W A T,6 a,
(� y
o -c
January 3, 2005
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Reason
PO 2201
Elizabethtown, North Carolina 28337
Subject: NOTICE OF VIOLATION/NOTICE OF INTENT
North Carolina General Statutes 143 - 215
Reason Farms #1 & # 2
Facility No. 9 - 16•
Bladen County
Dear Mr. Reason:
Michael F. Easley. Governor
William G. Ross Jr., Secretary,
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
You are hereby notified that, having been permitted to have a NPDES Permit for the subject animal waste disposal
system pursuant to NCGS 143 - 215, you have been found to be in violation of your NPDES Permit.
Violation 1: Failure to maintain adequate records as required by your NPDES Permit. (Permit No.
NCA290016 Section 3 condition 10 of the facility's NPDES Permit.)
This violation is in reference to Reason Farms having only one documented analyzed waste sample during the
2004 crop cycle at the time of inspection. Permit conditions requiring records of crop yield information must be
followed. The documentation of the annual irrigation equipment calibration had not been completed. The use of
approved forms to record waste treatment inspections both monthly and after one or greater storm events was
inadequate. Further the Certificate of Coverage and a copy of the Permit were not in the farm records at the time of
inspection.
Required Corrective Action for Violation 1:
Please maintain the Certificate of Coverage and a copy of your Permit with the farm records. Also immediately
begin to follow all conditions of your permit and Certified Animal Waste Management Plan (CAWMP). This includes
all documentation and recordkeeping for compliance with your NPDES Permit and your CAWMP.
Violation 2: Failure to follow the CAWMP.
The inspection conducted on 12/21/04 documented continued noncompliance with the CAWMP and Permit
Conditions as sited in the NOV/NOI of October 12,2004. During the 2004 crop cycle soybeans were planted as a
receiving crop and they were not part of the CAWMP for this farm at that time. Later an amendment was added but
not in the allotted time frame.
The Bermuda fields had not been overseeded as of 12/21/04 and in many areas the Bermuda stand is not
adequate as a receiving crop.
NAhCarolina
Natura!!Y
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal opportunitylAffirrnative Action Employer - 5TI. Recycled110°% Post Consumer Paper

Mr. Reason
January 3, 2005
Page 2
On 12/21/04 staff from the Fayetteville Regional Office conducted a Compliance Inspection at facility 9 — 16 and
on that date the lagoon levels were lagoon # 1 at 18" and lagoon # 2 at 19.5". It was brought to your attention at
that time that no notification had been received and a 30 day Plan of Action should be submitted within 48 hours for
lagoon # 1. As of 12/29/04 no Plan of Action has been received_
Previously on 9/9/04 a lagoon level was documented at 16" in lagoon # 2 and a Notice of Violation/Notice of
Intent was sent certified mail to you. The NOV/NOI dated October 12, 2004 was signed for by a Ms_ Becky Warren
on the 13t' of October 2004.This document specified that a Plan of Action must be submitted within 48 hours to the
Fayetteville Regional Office. It also specified other requested information and expectations of your facility to
achieve compliance. To date no response was received by this office. A copy of this document is included with
this mailing. Failure to respond is an enforceable permit violation. The expectations of that October 12, 2004
NOV/NOI are still required for your farm to comply. They are:
-Within 60 days of receipt of this notice please obtain and submit a comprehensive review report of your CAWMP
by a Technical Specialist. The purpose of the requested review is to identify the cause(s) of the facility not being
able to maintain adequate freeboard in it's structures and must contain corrective action taken or proposed to
improve the facility's compliance-
-Submit weekly update reports by telephone, fax, or email by 11:00 AM each Monday to the Fayetteville Regional
Office indicating, (1) the structure liquid level(s) and (2) total volume of waste irrigated or removed from the system
for the seven days prior to the report date. Transfers between the two lagoons should be included. These weekly
updates should continue until all structures are greater than 19 inches.
-Provide a detailed written explanation of how the farm will gain and maintain compliance of its lagoon levels,
CAWMP and Permit in the year 2005.
Violation 3: Failure to notify the Division of Water Quality of inadequate freeboard in a waste structure(s)
within 24 hours. (Permit No. NCA290016 Section III Condition 11e)
Your permit specially 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. The Division of Water Quality has no
record of receiving the 24- hour notification or the 5-day written report.
Required Corrective Action:
In the future, please notify the Division of Water Quality of the occurrence of any reportable events in accordance
with your permit. Failure to make or provide the appropriate notification(s) will result in issuance of civil penalties.
Violation 4: Failure to maintain waste levels in your waste structure(s) in accordance with the facilities
Certified Animal waste Management Plan. (Permit No. NCA290016 Section V Condition 3).
On 12/21/04 a lagoon/storage pond level was documented at 18 inches of freeboard at Reason Farm #1 lagoon. A
level of 19 inches is the maximum level allowed by your permit.
Please be advised that this notice does not prevent the Division of Water Quality from taking enforcement actions
for these violation or any past or future violation. Furthermore, the Division of Water Quality has the authority to
levy a civil penalty of not more than $25,000.00 per day per violation.

Mr. Ray Reason
January 3, 2005
Page 3
It is the opinion of this office that the events surrounding your farm and the history of noncompliance that it
continues to build demonstrates poor operation and management. This trend is not in the best interest of any of the
parties associated with Reason Farms #1 & #2 and requires a new commitment to following all aspects of the
Permit and CAWMP that are within the Permittees control_ This office will assist in any manner possible but all
responsibilities for permit compliance are the permittees. This office will conduct more frequent inspections at the
facility during the 2005-year and it is the expectation that you will be present at those inspections to discuss the
condition of the farm at that time_
If you have any questions concerning this matter, please do not hesitate to contact Mr. Larry C. Baxley,
Environmental Specialist, or myself at [phone].
Sincerely,
�St
. Barnhardt
Regio Aquifer Protection Supervisor
cc: Keith Larick - Compliance Group
Chris Bordeaux - Bladen Co_ MRCS
Trent Allen — SWC, FRO
Central Files - Raleigh

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Departraent of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
October 12, 2004
CERTIFIED MAIL_
RETURN RECEIPT REQUESTED
Mr. Ray Reason
PO 2201
Elizabethtown, North Carolina 28337
Subject: NOTICE OF VIOLATIONINOTICE OF INTENT
NCGS 143-215 et seq. & Section 402 of the Clean Water Act
Reason Farms #1 & # 2
Facility No. 9-16 -
Bladen County
Permit No. NCA290016
Dear Mr. Reason:
You are hereby notified that, having been permitted to have a National Pollutant Discharge Elimination (NPDES)
permit for the subject animal waste disposal system pursuant to N. C. General Statutes 143-215 et seq. and
Section 402 of the Clean Water Act, you have been found to be in Violation of your NPDES Permit
Violation 1: Failure to notify Division of Water Quality of inadequate freeboard in waste structure(s) within
24 hours. (Permit No. NCA290016 Section III Condition 11e)
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. The
Division of Water Quality has no record of receiving the 24-hour notification or the 5 day written
report.
Required Corrective Action for Violation 1:
In the future, please notify the Division of Water Quality of the occurrence of any reportable events
in accordance with your permit.
Violation 2: Failure to maintain waste levels in your waste structure(s) in accordance with the facilities
Certified Animal Waste Management Plan. (Permit No. NCA290016 Section V Condition 3)
On September 9, 2004 a lagoon/storage pond level was documented at 16 inches of freeboard at
Reason Farms #2 lagoon. A level of 19 inches is the maximum level allowed by your permit.
Required Corrective Action for Violation 2:
Submit a Plan of Action (POA) within 48 hours of receipt of this letter that will indicate how you
propose to lower the lagoon level to greater.than 19 inches of freeboard over the next 30 days. Take
all necessary additional steps to insure lagoon levels remain in compliance with Section V Condition 3
of your permit. Wyo-jittC !�a
North Carolina Division of Water Quality/Aquifer Protection Section 225 Green SU Suite 714 Fayetteville, NC 29301 Phone [phone]
FAX [phone] Inlemet h2o.enrst3te.nc.us Customer Service 1-877-623-6748
An Equal Opportun4lAftmative Action Employer — 50% Recycled140% Post Consumer Paper

A
•
S.
Mr. Reason
October 11, 2004
Page 2
Violation 3: Failure to abide by your CAWMP conditions during 2003 — 2004. (Permit No. NCA290016
Section I Condition 3, Section II Condition 1 and Condition 4) These are as follows:
Section I Condition 3: The facility's COC and its CAWMP are hereby incorporated by
reference into this permit. The CAWMP must be consistent with all applicable laws, rules,
ordinances, and standards (federal, state and local) in effect at the time of siting, design, and
certification of the facility. The Permittee must asses, on an ongoing basis, the effectiveness of
the implementation of the CAWMP. The Permittee must amend the CAWMP in order to address
any changes needed to maintain compliance with the facility's COC and this permit. Any
amendment to the CAWMP must be documented, dated, and included as part of the CAWMP.
All amendments, along with an explanation identifying all amendments, shall be submitted to the
appropriate Division regional office within ten (10) working days of the amendment.
Section II Condition 1: The collection, treatment, and storage facilities, and the land
application equipment and fields shall be properly maintained at all times.
Section II Condition 4: Land application rates shall be in accordance with the CAWMP. In no
case shall land application rates exceed the Plant Available Nitrogen rate for the receiving crop.
Required Corrective Action for Violation 3.
1. Follow all guidance within your approved CAWMP unless it is revised or amended properly.
2. Never allow Plant Available Nitrogen rates to be exceeded by animal waste applications.
Violation 4: Failure to apply animal waste at rates in accordance with your permit and Certified Animal
Waste Management Plan: (Permit No. NCA290016 Section II Condition 4 )
Records you have submitted to the division for cumulative plant available nitrogen applied at your
facility indicate over application during the 2003-2004 season.
Required Corrective action for Violation 4:
If you have not already done so, immediately cease application methods of animal waste that causes
or contributes to the over application on nutrients and take all necessary steps to insure this violation
does not reoccur. The steps could include but are not limited to modification of your Certified Animal
Waste Management Plan and/or adjustment and calibration of the spray irrigation equipment.

r
P
Mr. Ray Reason
October 11, 2004
Page 3
The Division of Water Quality requests that, in addition to the specified corrective actions above, please submit the
following items on or before October 27, 2004 unless another time frame is indicated below:
-Within 60 days of receipt of this notice please obtain and submit a comprehensive review report of
your CAWMP by Technical Specialist. The purpose of this review is to identify the cause(s) of the
facility not being able maintain adequate freeboard in it's structures and must contain any corrective
action taken or proposed to improve the facility's compliance.
-Submit weekly update reports by 11:00 AM each Monday indicating, (1) the structure liquid level(s)
and (2) total volume of waste irrigated or removed from the system for the seven days prior to the
report, date. These weekly update reports should continue until all structures are greater than 19
inches.
-Provide a detailed written explanation of how the farm will maintain compliance of its lagoon levels
this fail.
Please be advised that this notice does not prevent the Division of Water Quality from taking enforcement actions
for these violation or any past or future violation. Furthermore, the Division of Water Quality has the authority to
levy a civil penalty of not more than $25,000.00 per day per violation.
If you have an explanation for these violations that you wish to present to this office, please forward a detailed
explanation, in writing, of the event noted and why you feel that this office should not proceed with recommendation
for enforcement. This office should receive information in the time frame requested within this letter. Information
provided to this office will be reviewed and, if enforcement is still deemed appropriate, your explanation will be
forwarded to the Director with the enforcement package for his consideration.
If you have any questions concerning this matter, please do not hesitate to contact Mr. Lary C. Baxley,
Environmental Specialist, or myself at [phone].
Sincerely, �j
y
Stephen A. Barnhardt
Regional Aquifer Protection Supervisor
cc: Keith Larick - Compliance Group
Chris Bordeaux - Bladen Co. NRCS
Trent Allen - SWC, FRO
Central Files - Raleigh

Michael F. Easley, Governor
to r
September 16, 2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Reason
PO 2201 -
Elizabethtown, North Carolina 28337
Subject: NOTICE OF VIOLATION/NOTICE OF INTENT
North Carolina General Statutes 143 - 215
Reason Farms #1 & # 2
-Facility No. 9 - 16
Bladen County
Dear Mr. Reason:
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E_ Director
Division of Water Quality
You are hereby notified that, having been permitted to have a non -discharge permit for the subject animal waste
disposal system pursuant to NCGS 143 - 215, you have been found to be in violation of your NPDES Permit.
Violation 1: Failure to notify Division of Water Quality of inadequate freeboard in the lagoon within 24
hours. (Permit No. NCA290016 Section 3 condition 11e and Section 5 condition 3 of the
facility's NPDES Permit.)
This violation is in reference to Reason Farms #2 (Facility # 09 - 16) being in the storm storage according to your
CAWMP and failure to report.
Required Corrective Action for Violation 1:
Please notify the Division of Water Quality of any high freeboard occurrences within twenty fours hours.
The Division of Water Quality requests that in addition to the specified corrective action above, please submit the
following items on or before October 6, 2004:
1. Copies of all lagoon levels and rainfall records for this farm from January 1, 2004 to the present along with
a current copy of your CAWMP.
2. Please have the OIC for this farm include an explanation as to how this violation occurred.
3. Please have the OIC include a list of the steps that will be taken to prevent this violation from occurring in
the future.
N w Carolina
r>Furallz�
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Intemet h2o.emstale.mus 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equai OpportuNtylAffirmative Action Employer — 500% Recycledli 0% Post Consuner Paper

Mr. Reason
September 16, 2004
Page 2
Please be advised that this notice does not prevent the Division of Water Quality from taking enforcement actions
for these violation or any past or future violation. Furthermore, the Division of Water Quality has the authority to
levy a civil penalty of not more than $25,000.00 per day per violation.
If you have an explanation for this violation that you wish to present to this office, please forward a detailed
explanation, in writing, of the event noted and why you feel that this office should not proceed with recommendation
for enforcement. This office on or before October_6, 2004 should receive this response. Information, provided to
this office will be reviewed and, if enforcement is still deemed appropriate, your explanation will be forwarded to the
Director with the enforcement package for his consideration.
If you have any questions concerning this matter, please do not hesitate to contact Mr. Larry C. Baxley,
Environmental Specialist, or myself at [phone].
Sincerely,
Stephen amhardt
Regional Aquifer Protection Supervisor
cc_ Keith Larick - Compliance Group
Chris Bordeaux - Bladen Co. NRCS
Trent Allen — SWC, FRO
Central Files - Raleigh

WA7F�Q
�O G
� r
Michael F. Easley
Governor
William G. Ross Jr-, Secretary
Department of Environment and Natural Resources
t�j Alan W. Klimek, P.E. Director
Division of Water Quality
CERTIFIED MAIL
RETURN_ RECEIPT REQUESTED
Ray Reason
PO Box 2201
Elizabethtown NC 28337
SUBJECT. Notice of Violation
Request for Information
Inadequate Freeboard
Reason Farms 1 & 2
#9-1 b
Bladen County
Dear Sir or Madam:
April 15, 2003 — — — --
AR 2 3 2003
On February 28, 2003, a representative of your animal operation informed the Division of
Water Quality (DWQ) that there was inadequate freeboard in the lagoon(s) serving this facility.
This lack of adequate freeboard is in non-compliance with the Certificate of Coverage
issued to this facility on November 17, 1997. In addition to this Notice of Violation (NOV), this
non-compliance is subject to an appropriate enforcement action by DWQ. This action can
consist of one or more of the following: a civil or criminal enforcement action; an injunction;
and/or a requirement to apply for coverage under an individual permit. The action chosen will
be based on complete evaluation of all factors that resulted in the inadequate freeboard; the
actions taken to restore the needed freeboard; and the actions being proposed to prevent the
problem from reoccurring.
To assist us in our review, please provide the Fayetteville Regional Office with an
evaluation of the reasons for the freeboard violation(s) and a strategy to prevent future freeboard
violation(s). This evaluation and strategy must include but is not limited to the following:
Current Freeboard level(s)
Freeboard level records in the lagoon(s) for the past 12 months up to the date of submittal
Spraying records for the past 12 months up to the date of submittal
Customer Service: Mailing Address: Telephone [phone]
1-877-623-6748 1617 Mail Service Center Fax [phone]
Raleigh, North Carolina 27699-1617 State Courier #52-01-01
An Equal Opportunity /AtlimiativeAction Employer
50% recycled / 10% post -consumer paper
http://h2o.enr.state.nc. us
NCDENR
Location:
512 N. Salisbury St.
Raleigh, NC 27699-1617

Inadequate Freeboard
Page 2
Rainfall records for the past 12 months for this site up to the date of submittal (if
available)
Cropping system and PAN specified in the CAWMP. If the cropping system was not in
compliance with the facility's CAWMP, provide details of the cropping system in place
for the past 12 months.
A summary of actions taken to restore the needed freeboard in the lagoon(s) including but
not limited to removal of animals from the site, delay of restocking of animals, pumping
and hauling waste to another site (specify site), securing additional irrigation equipment,
and securing additional spray sites.
A description of water conservation measures in use at the facility and the date(s)
installed.
If the lagoon level(s) are still in violation of the facility's CAWMP and Permit, provide
an updated Plan of Action as to how the facility will return to compliance.
Provide a detailed description of the actions taken or proposed to be taken to insure that
there are no further freeboard violations at this facility.
This information must be received by the Fayetteville Regional Office at the following
address no later than 10 days following receipt of this letter.
Division of Water Quality
225 Green Street, Suite 714
Fayetteville, NC 28301-5043
Once this information is received and evaluated by the DWQ staff, a determination will
be made as to the appropriate compliance/enforcement actions to be taken. Each case will be
evaluated on its own merit. The efforts by the owner/producer to notify DWQ of the problem,
efforts made to resolve the problem once identified, and efforts proposed to prevent future
problems will be positive factors in this determination.
Nothing in this letter should be taken, as removing from you either the responsibility or
liability for this non-compliance or future cases of non-compliance. If you have any questions
regarding this letter, please do not hesitate to contact our Fayetteville Regional Office Staff at
[phone].
Sincerely,
. W X47��
an W. Klimek, P.E.
Director
cc: Fayetteville Regional Office
Non -Discharge Compliance/Enforcement Unit
Central Files

* - S
STATE OF NORTH CAROLINA NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
COUNTY OF BLADEN
File No. PC 04-013
IN THE MATTER OF
RAY REASON )
FOR NPDES GENERAL ) FINDINGS AND DECISION
PERMIT VIOLATIONS ) AND ASSESSMENT OF
CIVIL PENALTIES
Acting pursuant to delegation provided by the Secretary of the Department of
Environment and Natural Resources and the Director of the Division of Water Quality, 1, Jeffrey
O. Poupart, make the following:
I. FINDINGS OF FACT:
A. Ray Reason owns and operates the Ray Reason Farms 1 & 2, a swine operation in
Bladen County.
B. Ray Reason was issued Certificate of Coverage NCA209016 under NPDES
General Permit NCA200000 for Ray Reason Farm 1 & 2 on April 9, 2003,
effective April 9, 2003, with an expiration date of July 1, 2007.
C. Condition No. V.3 of the General Permit states in part, "The maximum waste
level in lagoons/storage ponds shall not exceed that specified in the CAWMP
(Certified Animal Waste Management Plan)- 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 stone event plus an additional one (1) foot
of structural freeboard."
D. Based on the 25-year, 24-hour storm event of seven (7) inches and one foot of
required structural freeboard, the waste level in the lagoon for Ray Reason Farm 1
& 2 shall not exceed Nineteen (19) inches.
E. Condition No. III. 11 e of the General Permit requires that the permittee shall
report by telephone to the appropriate Regional Office as soon as possible, but in
no case more than 24 hours following first knowledge of the occurrence of failure
to maintain storage capacity in a lagoon/storage pond greater than or equal to that
required in Condition V.3 of the issued permit.

F. DWQ staff from the Fayetteville Regional Office inspected Ray Reason Farm 1 &
2 on September 9, 2004 and observed that the waste level of lagoon identified as
#2 was sixteen (16) inches, which exceeded the level specified in the CAWMP.
G. The Fayetteville Regional Office has no record of notification from Ray Reason or
his representative(s) of the waste lagoon level exceeding that specified in the
CAWMP.
H. The Fayetteville Regional Office has not received the information requested in the
Notices of Violation dated September 16, 2004 and October 12, 2004 from Ray
Reason or his representative(s). This information includes the submittal of a 30
day Plan of Action to lower the waste lagoon to a compliant level, weekly update
reports until waste lagoon level reaches compliance and a written explanation of
how the facility will maintain waste lagoon level compliance throughout the fall
growing season.
I. The Fayetteville Regional Office has issued multiple Notices of Violation (NOV)
and also established through inspections and other documentation, failure to
comply with the CAWMP and Permit Conditions at this facility. The following is
a partial list of documents verifying these facts: Notices of Violation dated April
15, 2003, October 20, 2003, September 16, 2004, October 12, 2004; Inspection
Recorris dated May 21, 2003, December 4, 2003, January 21, 2004, February 27,
2004, September 9, 2004; Technical Assistance Site Visit Report dated September
27, 2004.
J. The costs to the State of the enforcement procedures in this matter totaled
$621.14.
Based upon the above Findings of Fact, I make the following:
II. CONCLUSIONS OF LAW:
A. Ray Reason is a "person" within the meaning of G.S. 143-215.6A pursuant to G.S.
143-212(4),
B. A permit for an animal waste management system is required by G.S. 143-215.1.
C. The above -cited failure to maintain the liquid level in the lagoon at the level
specified in the CAWMP violated Condition No. V.3 of the NPDES General
Permit.

D. The above -cited failure to report by telephone to the appropriate Regional Office
as soon as possible, but in no case more than 24 hours following first knowledge
of the occurrence of failure to maintain storage capacity in a lagoon/storage pond
greater than or equal to that required in Condition No. V. 3 violated Condition No.
III 1 Le of the NPDES General Permit.
E. The above -cited failure to provide requested information in the Notices of
Violation dated September 16, 2004 and October 12, 2004 violated Condition No.
11113. of the General Permit.
F. Ray Reason may be assessed civil penalties pursuant to G.S. 143-215.6A(a)(2)
which provides that a civil penalty of not more than ten thousand dollars
($25,000.00) per violation may be assessed against a person who violates or fails
to act in accordance with the terms, conditions, or requirements of a permit
required by G.S. 143-215.1.
G. The State's enforcement costs in this matter may be assessed against Ray Reason
pursuant to G.S. 143-215.3(a)(9) and G.S. 14313-282. 1 (b)(8).
H. The Supervisor of the Non -Discharge Compliance and Enforcement Unit,
Division of Water Quality, pursuant to delegation provided by the Secretary of the
Department of Environment and Natural Resources and the Director of the
Division of Water Quality, has the authority to assess civil penalties in this matter.

Based upon the above Findings of Fact and Conclusions of Law, I make the following:
M. DECISION:
Ray Reason is hereby assessed a civil penalty of:
$ for violating Condition No. V.3 of the General Permit by
failing to maintain the liquid level in the lagoon at the level
specified in the CAWMP
for violating Condition No. III I Le. of the General Permit
by failing to report by telephone to the appropriate Regional
Office as soon as possible, but in no case more than 24
hours following first knowledge of the occurrence of failure
to maintain storage capacity in a lagoon/storage pond
greater than or equal to that required in Condition No. V.3.
$ for violating Condition No. Ill 13. of the General Permit by
failing to provide information requested in the Notices of
Violation dated September 16, 2004 and October 12, 2004.
621.14 Enforcement costs
$ TOTAL AMOUNT DUE
As required by G.S. 143-215.6A(c), in determining the amount of the penalty I considered
the factors listed in G.S. 143B-282.1(b), which are-
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
and
(8) The cost to the State of the enforcement procedures.
(Date) Jeffrey O. Poupart, Supervisor
Non -Discharge Compliance and Enforcement Unit
Division of Water Quality

Violator:
Farm Name:
Contact Person:
Address:
Facility #:
Receiving Stream:
Classification:
Regional Office:
Inspector:
Report Prepared By:
Date: 11-22-04
DIVISION OF WATER QUALITY
ANIMAL OPERATIONS
ENFORCEMENT CASE REPORT
Mr. Ray Reason
Reason # 1 & #2 Farm
Ray Reason
Rosendale Road
09-16
N/A
N/A
Fayetteville
Larry Baxley, Hugie White
Larry Baxley & Stephen Barnhardt
On 9/9/04 5:00 pm, Hughie White inspected the lagoon level at Reason 1 and 2 Farms and noted
the freeboard at 16 inches in the Reason 1 lagoon. No notification of freeboard problem had
been received at the time of the inspection. No written or other response of any type has been
received as of 11-22-04 after repeated attempts of making contact. A Notice of Violation was
sent on September 16, 2004 for the above violations. An additional Notice of Violation was sent
on October 12, 2004, for continued freeboard violations and failure to comply with the facility's
CAWMP.
Mr. Reason's Farm has a long history of regulatory problems. The farm has application site
problems because a majority of the acreage is too wet for much of the year to apply to. Also
these fields are unable to support the crops designated in the CAWMP. Below is a partial list of
the past problems noted to date:
6-17-97 NOD for no cover crop
1-28-98 NOV for insufficient freeboard, no winter crop, Iagoon dikes without suitable
vegetation.
2-12-98 NOV for discharge of waste from spray fields on 2-11-98
3-3-98 NOV for nonpayment of annual fee
5-27-98 Notice of recommendation of Enforcement for discharge of waste to surface
waters
10-16-98 Assessment of Civil Penalty $4,460.49
2-26-99
NOV for nonpayment of annual fee
7-30-99
NOD for lack of lagoon vegetation, crops in poor condition, records incomplete
2-23-00
NOV for nonpayment of annual fee
3-17-00
NOD for freeboard of 16"
3-20-00
NOV for nonpayment of annual fee

Page 2
Ray Reason Enforcement Report
9-8-00
NOV for poor crops
2-1-01
NOV for nonpayment of annual fee
6-12-01
NOV for poor crops, wrong crop management
2-11-02
NOV for nonpayment of annual fee
2-28-02
Farm reported high freeboard
3-18-03
NOV for nonpayment of annual fee
4-15-03
NOV/Request for Info about freeboard violations
10-20-03
NOV/Recommend Enforcement for freeboard violation w/ failure to report (12-
23-02 through at least 4-14-03 lagoon records)
12-4-03
Freeboard violation continues -15"
3-5-04
NOV for nonpayment of annual fee
9-09-04
Unreported freeboard violation discovered -16"
9-16-04
NOV for high freeboard
9-27-04
Freeboard violation continues -16"
10-12-04
NOV for continuing freeboard and CAWMP violations
10-18-04
Freeboard violation continues -16"
Violator's degree of canperation (including efforts to prevent or restore) recalcitrance:
Mr. Reason has failed to respond to the high freeboard Notice of Violation sent 9-16-04 or the
subsequent Notice of Violation sent 10-12-04. The history of this facility indicates that Mr.
Reason is not willing to take the necessary steps to bring this facility into compliance.
I IF
Mitigating Circumctnnces_
None.
Reenmmendatinn:
The Fayetteville Regional Office is recommending assessment of civil penalties to the Director
of the Division of Water Quality pursuant to G.S. 143-215.6A.
Include a copy of the previously completed Animal Operations Inspection Form, pictures and
site sketch of waste flow if waste is discharged to surface waters. Also include violator's
response to Notice of Recommendation for Enforcement. If citing certified plan or permit
condition violations, include copies ofpermit or plan.
The degree and extent of harm to the natural resources of the State, to the public health, or
to private property resulting from violation:
In reference to the cited violations, no harm to the natural resources of the State were
documented.

Page 3
Ray Reason Enforcement Report
The duration and gravity of the violation:
For the waste lagoon level violation, the Reason 1 lagoon has been at a level within the storm
event storage from at least September 9, 2004 through October 18, 2004 when it was last
checked by DWQ. Storm event storage is roughly equal to 7 inches of water, designed to contain
a severe rain events without the waste level reaching critical heights inside the lagoon. Both
times the lagoon was checked by DWQ, only 4 inches of storm event storage was present. The
possibility exists that a weather system could produce enough rain to threaten the structural
stability of this lagoon.
The effect on ground or surface water quantity or quality:
No water quality monitoring is currently ongoing. Therefore no data exists to determine this
factor.
The cost of rectifying the damage:
This factor cannot be determined because no data exists to establish the extent of (or if) any
damage has occurred.
The amount of money saved by noncompliance:
The cost of developing and implementing a 30 Plan of Action, collection and submittal of
requested information is difficult to establish with the information that the Division currently has
but is not expected to be significant.
Whether the violation was committed willfully or intentionally:
The permittee has made a conscious decision to violate the conditions of the permit by not taking
the necessary steps to comply with the CAWMP and General Permit.
The prior record of the violator in complying or failing to comply with programs over
which the Environmental Management Commission has regulatory authority:
Very poor. See previous discussion on compliance history.
Summary of Enforcement Cost:
The cost to the State of the enforcement procedures:
Staff, Baxley
4 hours @20.46/hr
$81.84
Staff, Bennett
2 hours @ 26.90/hr
$53.80
Staff, Brantley
2 hours @19.94/hr
$39.88
Supervisor, Barnhardt
9 hours @29.36/hr
$264.24
Certified Mail
2 @ $4.42
$8.84
Central Office Administrative Cost
$100
Mileage
2 trips 234 mi@ $.31
$72.54
Total
$621.14

0 dT
5 —,
William G. Ross Jr.. Secretary
North Carolina Department of Environment and Nawal Resources
. 0 .Ni� `C
October 12, 2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Reason.
PO 2201
Elizabethtown, North Carolina 28337
Subject: NOTICE OF VIOLATIONINOTICE OF INTENT
NCGS 143-215 et seq. & Section 402 of the Clean Water Act
Reason Farms #1 & # 2
Facility No. 9-16
Bladen County
Permit No. NCA290016
Dear Mr. Reason:
Alan W. Klimek, P.E. Director
Division of Water Quality
You are hereby notified that, having been permitted to have a National Pollutant Discharge Elimination (NPDES)
permit for the subject animal waste disposal system pursuant to N. C. General Statutes 143-215 et seq. and
Section 402 of the Clean Water Act, you have been found to be in violation of your NPDES Permit.
Violation 1: Failure to notify Division of Water Quality of inadequate freeboard In waste structure(s) within
24 hours. (Permit No. NCA290016 Section III Condition 11a)
Your permit specifically requires notification by telephone within 24 hours and a written report within
5 calendar days fbIlowing first knowledge of the occurrence of a reportable permit condition. The
Division of Water Quality has no record of receiving the 24-hour notification or the 5 day written
report.
Required Corrective Action for Violation 1:
In the future, please notify the Division of Water Quality of the occurrence of any reportable events
in accordance with your permit.
Violation 2: Failure to maintain waste levels In your waste structure(s) in accordance with the facilities
Certified Animal Waste Management Plan. (Permit No. NCA290016 Section V Condition 3)
On September 9, 2004 a lagoon/storage pond level was documented at 16 inches of freeboard at
Reason Farms #2 lagoon. A level of 19 inches is the maximum level allowed by your permit.
Required Corrective Action for Violation 2:
Submit a Plan of Action (POA) within 46 hours of receipt of this letter that will indicate how you
propose to lower the lagoon level to greater than 19 inches of freeboard over the next 30 days. Take
all necessary additional steps to insure lagoon levels remain in compliance with Section V Condition 3
of your permit. Carolina
Nam`
Aurally
North Carolina Division of Water Quality/Aquifer Protection Section 225 Green SU Suite 714 Fayetteville, NC 29301 Phone [phone]
FAX [phone] Intemet h2o.enr.state.mus Customer Service 1-877-623.6748
An Equal Opportunity/Affirmative Action Employer— 50% Recydedll0%Post Consumer Paper

Mr. Reason
October 11, 2004
Page 2
Violation 3: Failure to abide by your CAWMP conditions during 2003 — 2004. (Permit No. NCA290016
Section I Condition 3, Section II Condition 1 and Condition 4) These are as follows:
Section I Condition 3: The facility's COC and its CAWMP are hereby incorporated by
reference into this permit. The CAWMP must be consistent with all applicable laws, rules,
ordinances, and standards (federal, state and local) in effect at the time of siting, design, and
certification of the facility. The Permittee must asses, on an ongoing basis, the effectiveness of
the implementation of the CAWMP. The Permittee must amend the CAWMP in order to address
any changes needed to maintain compliance with the facility's COC and this permit. Any
amendment to the CAWMP must be documented, dated, and included as part of the CAWMP.
All amendments, along with an explanation identifying all amendments, shall be submitted to the
appropriate Division regional office within ten (10) working days of the amendment.
Section II Condition 1: The collection, treatment, and storage facilities, and the land
application equipment and fields shall be properly maintained at all times.
Section II Condition 4: Land application rates shall be in accordance with the CAWMP. in no
case shall land application rates exceed the Plant Available Nitrogen rate for the receiving crop.
Required Corrective Action for Violation 3.
1. Follow all guidance within your approved CAWMP unless it is revised or amended properly.
2. Never allow Plant Available Nitrogen rates to be exceeded by animal waste applications.
Violation 4: Failure to apply animal waste at rates in accordance with your permit and Certified Animal
Waste Management Plan: (Permit No. NCA290016 Section II Condition 4 )
Records you have submitted to the division for cumulative plant available nitrogen applied at your
facility indicate over application during the 2003-2004 season.
Required Corrective action for Violation 4:
If you have not already done so, immediately cease application methods of animal waste that causes
or contributes to the over application on nutrients and take all necessary steps to insure this violation
does not reoccur. The steps could include but are not limited to modification of your Certified Animal
Waste Management Plan and/or adjustment and calibration of the spray irrigation equipment.

qw.
Air. Ray Reason
October 11, 2004
Page 3
The Division of Water Quality requests that, in addition to the specified corrective actions above, please submit the
following items on or before October 27, 2004 unless another time frame is indicated below:
-Within 60 days of receipt of this notice please obtain and submit a comprehensive review report of
your CAWMP by Technical Specialist. The purpose of this review is to identify the cause(s) of the
facility not being able maintain adequate freeboard in it's structures and must contain any corrective
action taken or proposed to improve the facility's compliance.
-Submit weekly update reports by 11:00 AM each Monday indicating, (1) the structure liquid level(s)
and (2) total volume of waste irrigated or removed from the system for the seven days prior to the
report date. These weekly update reports should continue until all structures are greater than 19
inches.
-Provide a detailed written explanation of how the farm will maintain compliance of its lagoon levels
this fall.
Please be advised that this notice does not prevent the Division of Water Quality from taking enforcement actions
for these violation or any past or future violation. Furthermore, the Division of Water Quality has the authority to
levy a civil penalty of not more than $25,000.00 per day per violation.
If you have an explanation for these violations that you wish to present to this office, please forward a detailed
explanation, in writing, of the event noted and why you feel that this office should not proceed with recommendation
for enforcement. This office should receive information in the time frame requested within this letter. Information
provided to this office will be reviewed and, if enforcement is still deemed appropriate, your explanation will be
forwarded to the Director with the enforcement package for his consideration.
If you have any questions concerning this matter, please do not hesitate to contact Mr. Larry C. Baxley,
Environmental Specialist, or myself at [phone].
Sincerely, r� ;
Stephen A. Barnhardt
Regional Aquifer Protection Supervisor
cc: Keith Larkck - Compliance Group
Chris Bordeaux - Bladen Co. NRCS
Trent Allen - SWC, FRO
Central Files - Raleigh

of \N 4
`02 pG
June 10, 2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Reason
PO Box 2201
Elizabethtown, NC 28337
Subject: REOUEST FOR INFORMATION
Reason Farms 1 & 2
Facility No. 9-16
Bladen County
Dear Mr. Reason:
Michael F. Easley, Governor
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. E. Director
Over the past several months this office has attempted to document the extent of the actions
you have undertaken in order to regain compliance on Reason Farms 1 & 2. During this period
this office has held discussions and meetings with you on how these circumstances occurred, the
possible permit conditions that have been violated, and this office's expectations of the farm
regaining compliance in all areas of the permit. In order for this office to begin this final
assessment of these events some additional information is necessary.
The Division of Water Quality makes the following request: Submit copies of the following
information for Reason Farms 1 & 2.
A copy of the CAWMP that your farm is operating under now. Please include all
amendments or changes made in the past year.
2. A copy of the farm Wettable Acres Determination Information.
3. Copies of all the irrigation records for the past year until the present date.
4. Lagoon levels for the past year.
5. Identify the Operator in Charge for the farm.
Please send this requested information to the Fayetteville Regional Office. This office should
receive it on or before-JuIV 2 2004.
>CI
UW
N. C. Division of Water Quality 225 Green Street Fayetteville, North Carolina 28301-5043 [phone] Fax [phone] Customer Service
1-877-623-6748

4T,,I
/ Ray Reason
Page 2
6/ 10/04
If you have any questions concerning this matter, please do not hesitate to contact either Mr.
Larry Baxley, Environmental Specialist, or myself at [phone],
Regional Water Quality Supervisor
PR/lb
cc: Keith Larick - Compliance Group
Chris Bordeaux - Bladen Co. NRCS „
Trent Allen --- SWC, FRO
Central Files - Raleigh
For
NCDENR
N. C. Division of Water Quality 225 Green Street Fayetteville, North Carolina 28301-5043 [phone] Fax [phone] Customer service
1-877-623-6748

X ,
June 10, 2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Reason
PO Box 2201
Elizabethtown, NC 28337
Subject: REQUEST FOR INFORMATION
Reason Farms 1 & 2
Facility No. 9-1 b
Bladen County
Dear Mr. Reason:
Michael F. Easley, Governor
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. E. Director
DER-FRU
JUL 19 2m
Over the past several months this office has attempted to document the extent of the actions
you have undertaken in order to regain compliance on Reason Farms 1 & 2. During this period
this office has held discussions and meetings with you on how these circumstances occurred, the
possible permit conditions that have been violated, and this office's expectations of the farm
regaining compliance in all areas of the permit. In order for this office to begin this final
assessment of these events some additional information is necessary.
The Division of Water Quality makes the following request: Submit copies of the following
information for Reason Farms 1 & 2.
A copy of the CAWMP that your farm is operating under now. Please include all
amendments or changes made in the past year.
2. A copy of the farm Wettable Acres Determination Information.
3. Copies of all the irrigation records for the past year until the present date.
4. Lagoon levels for the past year.
Identify the Operator in Charge for the farm.
Please send this requested information to the Fayetteville Regional Office. This office should
receive it on or before July 2 2004.
AVA
NCDENR
N. C. Division of Water Quality 225 Green Street Fayetteville, North Carolina 2X301-5043 [phone] Fax [phone] Customer Service
i-877-623-6748

Ray Reason
Page 2
6/10/04
If you have any questions concerning this matter, please do not hesitate to contact either Mr_
Larry Baxley, Environmental Specialist, or myself at [phone].
Regional Water Quality Supervisor
PR/lb
cc: Keith Larick - Compliance Group
Chris Bordeaux - Bladen Co. NRCS
Trent Allen — SWC, FRO
Central Files - Raleigh
rh
NUDENR
N. C. Division of Water Quality 225 CTeen Street Fayetteville, North Carolina 28301-5043 [phone] Fax [phone] Customer Service
1-s77-623-6748

\NA
Michael F. Easley, Governor
O4
RQG
Division of Water Quality
Coleen H. Sullins, Deputy Director
`O�
y.
Division of Water Quality
r
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
0
Alan W. Klimek, P. E. Director
May 24, 2004
CERTIFIED MAIL
RETURN RECEIPT RE UESTED
Mr. Ray Reason
PO Box 2201
Elizabethtown, NC 28337
Subject: Farm Status and Update
Reason Farms 1 & 2
Facility No. 9-16
Bladen County
Dear Mr. Reason:
In an effort to be proactive and address issues before they develop into larger more complex
problems the Fayetteville Office of the Division of Water Quality would like to remind you that
we are now entering hurricane season. The National Weather Service is expecting a very active
season this year and we ask that you bear that in mind as you make decisions for managing
Reason Farms 1 & 2 and it's lagoons this year.
Staff members conducted a farm visit on May 14, 2004 and the lagoon levels were recorded
on that date. Lagoon number 1 was at 14" and number two was at 22". Review of office
information shows no current Plan of Action (POA) has been received for lagoon 41. In addition
the winter annual needed to be removed from the fields in order to promote growth of the Coastal
Bermuda. This is important due to the limited acres with a suitably established Coastal Bermuda
covering.
The Fayetteville Regional Office has been informed your farm is for sale but please be
advised all elements of the Permit and CAWMP must still be followed. Further, it is our
understanding that you have chosen to continue to keep your farm depopulated as part of your
plan to bring your farm back into compliance. This office encourages you to continue to manage
your waste handling system by all necessary means to once again bring your farm into full
compliance.
Based on the above, please provide your plan of action to bring lagoon #1 (Reason Farm # 1)
into compliance. Also, please provide this office with your strategy to build sufficient freeboard
to as adequately as possible maintain compliance if or when eastern North Carolina is subject to
hurricane like storm events this year. Please provide this requested information by June 15,
2004. 1
t�til�El
N. C. Division of Water Quality 225 Green Street Fayetteville. North Carolina 28301-5043 [phone] Fax [phone] Customer Service
1-877-623-6748

Mr. Ray Reason
5--24-04
Page 2
If you have any questions concerning this matter, please do not hesitate to contact either Mr.
Larry Baxley, Environmental Specialist, or myself at [phone].
STaulRaw2ls
Regional Water Quality Supervisor
PR/lb
cc: Keith Larick - Compliance Group
Chris -Bordeaux - Bladen Co. NRCS
Trent Allen — SWC, FRO
Central Files - Raleigh
N. C. Division of Water Quality 225 Green Street Fayetteville, North Carolina 28301-5043 [phone] Fax [phone]
rev.
ddcD
Customer Service
1-877-623-6748

CERTIFIED MAIL
RETURN RECEIPT REQUESTED
RAY REASON
PO Box 2201
ELIZABE HTowN NC 28337
Dear Ray Reason:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
DEAR -FRO
MAR - 5 2004
DWQ
Alan W. Klimek, P.E. Director
Division of Water Quality
February 20, 2004
Subject: Notice of Violation and Revocation for Nonpayment
Reason farms 1 & 2
Permit Number: NCA209016
Bladen County
In accordance with North Carolina General Statute 143-215.1OG, all animal operations who receive an animal
waste management system permit will be charged in each year of the term an annual,permit fee. Annual permit fees are
billed following the issuance of the permit and then annually thereafter on the anniversary of that date. Your animal waste
management system permit was issued on 4/9/2003.
Your annual permit fee for the period of 4/9/2003 - 4/8/2004 is $300.00, Your payment was due 1 /7/2004.
Because this fee was not fully paid within 30 days after being billed, this letter initiates action to revoke the subject permit,
pursuant to 15 NCAC 2H .0205 (c) (4). and G.S. 143-215.1 (b) (3).
Effective 60 days from receipt of this notice, the subject permit is hereby revoked unless the required Annual
Animal Waste Management System Permit fee for your animal operation is received within that time. Operation of an
animal waste management system without a valid permit is a violation of North Carolina General Statute 143-215.1 and is
subject to the assessment of a civil penalty of up to $10,000 per day. Your payment should be sent to:
N.C. Department of Environment and Natural Resources
Division of Water Quality
Budget Office
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If you have any questions, please contact Fran McPherson at [phone] ext. 210.
Sincerely,
Alan W. Klimek, P.E.
cc: Non -Discharge Branch Compliance/Enforcement Unit
Fayetteville Regional Office
Bladen County Health Department
Permit File
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled / 10% post -consumer paper

Michael F. Easley, Governor
Division of Water Quality
Coleen H_ Sullins, Deputy Director
Division of Water Quality
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. E. Director
February 2, 2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Reason .
PO Box 2201
Elizabethtown, NC 28337
Subject: NOTICE OF SHOW CAUSE MEETING
Administrative Code 15A NCAC 2H .0217
Reason Farms 1 & 2
Facility No. 09-16
Bladen County
Dear Mr. Reason
Recently, staff from the Fayetteville Regional Office of the Division of Water Quality
conducted a review of the records you submitted for your permitted, NCA209016, swine farm
located on Rosendale in Bladen County. Events of this past year have not been easy and require
difficult decisions to be made. During 2003 the Reason Farm I & 2 has spent approximately six
months of the time within the storm or structural liquid storage levels in the two lagoons. In
addressing these issues this office has three primary concerns.
1. What circumstances caused or contributed to the farm being in noncompliance?
2. What actions have been taken to regain compliance?
3. How will the farm maintain compliance in the future?
This in conjunction with this facilities history of compliance issues demonstrates to this
office that consistent and predictable compliance with your permit has been a problem.
Based on a brief file review your facility has had the following compliance history:
I . 06/17/97 NOD — No cover crop established.
2. 02/12/98 NOV- Discharge of waste from a spray field.
3. 01 /28/98 NOV-- Insufficient freeboard, dikes without suitable vegetation, no winter crop.
4. 03/03/98 NOV and Revocation for Nonpayment.
5. 05/27/98 Notice of Recommendation for Enforcement- Discharging wastewater to surface
waters.
6. 06/26/98 Notice of Recommendation for Enforcement- Discharging wastewater to waters of
the state on 2/ 11 /98.
7. 02/26/99 NOV and Revocation for Nonpayment.
8. 07/30/99 NOD Lagoon bank erosion, low areas in spray fields, not recording weekly lagoon
levels.
N. C. Division of Water Quality 225 Green street Fayetteville. North Carolina 28301-5043 [phone] Fax [phone]
NCDE-N t
Customer Service
1-877-623-6748

Mr. Reason
02-02-04
Page 2
9, 03/17/00 NOD — Notification of freeboard level of 16 inches.
10.03/20/00 NOV and Revocation for Nonpayment
11, 09/08/00 NOV — Inadequate crops to take up PAN. Lack of crop maintenance in spray fields.
12. 02/01 /01 NOV and Revocation for Nonpayment.
13.01/12/01 NOV/Recommendation for Enforcement — Cut and remove overseed, establish
required summer crop, and fix leaking pipe.
14.02/11/02 NOV and Revocation for Nonpayment.
15.03/18/03 NOV and Revocation for Nonpayment.
16. 04/15/03 NOV/RF1— Self reported freeboard. Consideration for Enforcement sent 10/20/03.
Due to the items discussed above the Fayetteville Regional Office is considering
recommending to the Director to take enforcement action in this case. The Fayetteville- Staff
would like to offer you the opportunity to discuss these issues and present information that you
feel would "show cause" for this office not to proceed with enforcement action.
This "Show Cause Meeting" would take place in the seventh floor conference room of the
Division of Water Quality Offices located in the Systel Building at 225 Green Street in
Fayetteville, North Carolina. You should bring any records, CAWP, diagrams or any other
information as to why the Division of Water Quality should not proceed with Enforcement
Action. The proposed date of the meeting is Thursday February 19, 2004 in the Seventh Floor
Conference Room at 1:00 pm that afternoon.
Please respond within 10 days of receipt of this letter to acknowledge your desire to discuss
this matter or this office will make final decisions pertaining to this case based on information
currently on hand.
If you have any questions concerning this matter, please do not hesitate to contact either
Mr. Larry Baxley, Environmental Specialist, or myself at [phone].
incer ,
J,
Paul E. Rawls
Regional Water Quality Supervisor
PR/lb
cc: Keith Larick - Compliance Group
Chris Bordeaux - Bladen Co. NRCS
Trent Allen — SWC, FRO
Central Files - Raleigh
AMA
N. C. Division of Water Quality 225 Green Street Fayetteville, North Carolina 29301-5043 [phone] Fax [phone] Customer Service
1-877-623-6749

F wAT Michael F. Easley, Governor
0 R Division of Water Quality
_O�QG Coleen H. Sullins, Deputy Director
y Division of Water Quality
S William G_ Roes Jr_, Secretary
'1 North Carolina Depann=x of Environment and Natural Resources
O 'C
Alan W. Klimek, P. E. Director
April 5, 2004
CERTIFIED MAIL
RETURN_ RECEIPT REQUESTED
Mr. Ray Reason
PO Box 2201
Elizabethtown, NC 28337
Subject: Wettable Acres Determination Request
Administrative Code 15A NCAC 21H .0217
Reason Farms l & 2
Facility No. 9-16
Bladen County ;
Dear Mr. Reason:
DER --FAQ
APR 15 2004
The Fayetteville Regional Office of the Division of Water Quality has been working with you
for some time addressing. ongoing compliance issues. Part of this effort has focused on file
review of items essential for proper waste management on Reason #1 & Reason # 2. The events
of the past five months suggest that there are items that need clarification. One of these is the
Wettable Acres Determination completed in 1999 by Technical Specialist, Sonya Barber.
Another is the fulfilling of the conditional certification of the farm.
By this letter we ask that you provide a copy of the Wettable Acres Determination and all
supporting documentation used to prepare it for your farm_ The additional information would be,
but not necessarily limited to, the wettable acres workshects and the r..aps exp.:ssing all of the
fields/pulls associated with the CAWMP. The conditional certification would be a signed form
indicating that the cover crop as required by the CAWMP was established by 6-30-98. We ask
that you submit this information b pril 16 2004 t the Fayetteville R ional Office.
This office encourages you to continue to follow your CAWMP in accordance with your
permit.
A�
NEUENR
N' C. )MSi.r, of WStcr `luality (accn Su -'et Y'ayettctiillC, North C'arplina 214301-5043 (910) 4S6,1541 Fax (910) 41S6-0707 Customer Service
1-877.623-6749

Mr_ Reason
04-5-04
Page 2
If you have any questions concerning this matter, please do not hesitate to contact either Mr.
Larry Baxley, Environmental Specialist, or myself at (91 U) 486-1541.
Sincerel ,
Paul E- Rawls
Regional Water Quality Supervisor
PR/lb
cc. Keith Larick - Compliance Group
Chris Bordeaux - Bladen Co. N RCS
Trent Allen — SWC, FRO
Central Files - Raleigh
AfA
}�i7EK#`c
N. C. Division of'WaLcr Quality 225 Green Street Fayeneville. North Carolina 28301-5043 (910)-U&-1541 Fax (910) 4X6-0707 Cum Service
I-x77-r23-67 a ti

Michael F. Easley, Governor
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
William G. Ross Jr., Secretary
North Carolina Deparunent of Envirom»ent and Natural Resources
Alan W. Klimek, P. E. Director
February 2, 2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr- Ray Reason .
PO Box 2201
Elizabethtown, NC 28337
Subject: NOTICE OF SHOW CAUSE MEETING
Administrative Code 15A NCAC 2H .0217
Reason Farms l & 2
Facility No. 09-16
Bladen County
Dear Mr. Reason:
Recently, staff from the Fayetteville Regional Office of the Division of Water Quality
conducted a review of the records you submitted for your permitted, NCA209016, swine farm
located on Rosendale in Bladen County. Events of this past year have not been easy and require
difficult decisions to be made. During 2003 the Reason Farm 1 & 2 has spent approximately six
months of the time within the storm or structural liquid storage levels in the two lagoons. In
addressing these issues this office has three primary concerns.
1. What circumstances caused or contributed to the farm being in noncompliance?
2. What actions have been taken to regain compliance?
3. How will the farm maintain compliance in the future?
This in conjunction with this facilities history of compliance issues demonstrates to this
office that consistent and predictable compliance with your permit has been a problem.
Based on a brief file review your facility has had the following compliance history:
I. 06/17/97 NOD — No cover crop established.
2. 02/12/98 NOV- Discharge of waste from a spray field.
3. 01/28/98 NOV- Insufficient freeboard, dikes without suitable vegetation, no winter crop.
4. 03/03/98 NOV and Revocation for Nonpayment.
5. 05/27/98 Notice of Recommendation] for Enforcement- Discharging wastewater to surface
waters.
6. 06/26/98 Notice of Recommendation for Enforcement- Discharging wastewater to waters of
the state on 2/ 11 /98.
7. 02/26/99 NOV and Revocation for Nonpayment.
8. 07/30/99 NOD Lagoon bank erosion, low areas in spray fields, not recording weekly lagoon
levels. 1XIM
0DEN
N. C. Division of Water Quality 225 Green Street Fayetteville, North Carolina 28301-5043 [phone] F&v [phone] Customer Service
1-877-623-6748

r
Mr. Reason
02-02-04
Page 2
9. 03/17/00 NOD — Notification of freeboard level of 16 inches.
10. 03/20/00 NOV and Revocation for Nonpayment
IL . 09/08/00 NOV — Inadequate crops to take up PAN. Lack of crop maintenance in spray fields.
12. 02/01/01 NOV and Revocation for Nonpayment.
13. 01 /12/01 NOV/Recommendation for Enforcement — Cut and remove overseed, establish
required summer crop, and fx'leaking pipe.
14. 02/11/02 NOV and Revocation for Nonpayment.
15. 03/18/03 NOV and Revocation for Nonpayment.
16.04/15/03 NOV/RFl -- Self reported freeboard. Consideration for Enforcement sent 10/20/03.
Due to the items discussed above the Fayetteville Regional Office is considering
recommending to the Director to take enforcement action in this case. The Fayetteville, Staff
would like to offer you the opportunity to discuss these issues and present information that you
feel would "show cause" for this office not to proceed with enforcement action.
This "Show Cause Meeting" would take place in the seventh floor conference room of the'
Division of Water Quality Offices located in the Systel Building at 225 Green Street in
Fayetteville, North Carolina. You should bring any records, CAWP, diagrams or any other
information as to why the Division of Water Quality should not proceed with Enforcement
Action. The proposed date of the meeting is Thursday February 19, 2004 in the Seventh Floor
Conference Room at 1:00 pm that afternoon.
Please respond within 10 days of receipt of this letter to acknowledge your desire to discuss
this matter or this office will make final decisions pertaining to this case based on information
currently on hand.
If you have any questions concerning this matter, please do not hesitate to contact either
Mr. Larry Baxley, Environmental Specialist, or myself at [phone].
lncer ,
Paul E. Rawls
Regional Water Quality Supervisor
!' : AZ
cc: Keith Larick - Compliance Group
Chris Bordeaux - Bladen Co. NRCS
Trent Allen -- SWC, FRO
Central Files - Raleigh
N. C. Division of Water Quality 225 Green Street Fayetteville, North Carolina 28301-5043 [phone] Fax [phone] Customer Service
1-877-623-6748

0 F \NA I'llI'llMichael
'QQG
F. Easley, Governor
Division of Water Quality
Coleen H. Sullins, Deputy Director
�QZ
y
Division of Water Quality
William G. Ross Jr., Secretary
North Carolina Department of Enviromnent and Natural Resources
0
Alan W. Klimek, P_ E. Director
January 20, 2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Reason
PO Box 2201
Elizabethtown, NC 28337
Subject: Farm Status and Update
Administrative Code 1 5A NCAC 2H .0217
Reason Farms 1 & 2
Facility No. 9-16
Bladen County
Dear Mr. Reason:
Recently, staff from the Fayetteville Regional Office of the Division of Water Quality have
been working with you for your permitted, NCA209016, swine farm located on Rosendale in
Bladen County. This letter serves as a follow up to the events that have occurred over the past
few months -
In November of 2003 staff member Larry Baxley visited your farms and became concerned
that given the lagoons liquid levels and CAWMP PAN limits the farms would have problems
through the traditionally wet winter months. After questions arose over the accuracy of the lagoon
markers the lagoons actual levels were checked and found to be at seriously high freeboard
levels. One, in fact, was in the structural storage limits. This office considers that to be an
emergency situation and must be responded to within five days. Every reasonable effort must be
made to achieve compliance without violating the Permit.
The options available to regain compliance are choices the grower and integrator make for
their particular situation. Common responses are water conservation procedures and with the
weather permitting to apply to their spray fields within the permit guidelines. Another option
would be to pump and haul the waste to another legal site. Culling of animals from the
confinement houses and depopulation help to reduce the waste flow into the lagoons and thus the
volume that has to be removed to achieve compliance. Modification of the CAWMP to
incorporate more land or better -suited crops can also be done with the help of technical
specialist. This plan of action items to take can be implemented singularly or in combination
depending on the severity of each situation.
Since this event started staff has met with you and representatives of the company you
contract grow for in order that all parties cooperate to protect the environment and assist your
farm in regaining compliance. It is the opinion of this office that restocking should not take place
until compliance has been achieved. Delayed restocking is a point that has been agreed upon by
both the producer and the integrator in this case. Mr. Reason currently has seven confinement
barns of his twenty that. are empty.
NS
N. C. Division of Water Quality 225 Green Street Fayetteville, North Carolina 28301-5043 [phone] Fax [phone] Customer Service
1-877-623-6748

Mr. Ray Reason
01-20-04
Page 2
This office encourages you to continue to expand your waste handling options by all means
that are in accordance with your permit. While events of the past cannot be changed this office
recognizes your recent efforts and looks ahead to working with you in the future.
If you have any questions concerning this matter, please do not hesitate to contact either Mr.
Larry Baxley, Environmental Specialist, or myself at [phone].
Paul E. Rawls
Regional Water Quality Supervisor
1
cc: Keith Urick - Compliance Group
Chris Bordeaux - Bladen Co. NRCS
Trent Allen — SWC, FRO
Central Files - Raleigh
t * R
N. C. Division of Water Quality 225 Green Street Fayetteville, North Carolina 28301-5043 (910) 486-) 541 Fax [phone] Custorner Service
1-877-623-6748

Michael F. Easley, Governor
`O� 9QG Division of Water Quality
Coleen H. Sullins, Deputy Director
y Division of Water Quality
r William G. Ross Jr., Secretary
i North Carolina Depanment of Environment and Natural Resources
Alan W. Klimek, P. E. Dit=tor
January 20, 2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Reason
PO Box 2201
glizabethtown, NC 28337
Subject: Farm Status and Update
Administrative Code 15A NCAC 2H .0217
Reason Farms 1 & 2
Facility No. 9-16
Bladen County
Dear Mr. Reason:
Recently, staff from the Fayetteville Regional Office of the Division of Water Quality have
been working with you for your permitted, NCA209016, swine farm located on Rosendale in
Bladen County. This letter serves as a follow up to the events that have occurred over the past
few months.
In November of 2003 staff member Larry Baxley visited your farms and became concerned
that given the lagoons liquid levels and CAWMP PAN limits the farms would have problems
through the traditionally wet winter months. After questions arose over the accuracy of the lagoon
markers the lagoons actual levels were checked and found to be at seriously high freeboard
levels. One, in fact, was in the structural storage limits. This office considers that to be an
emergency situation and must be responded to within five days_ Every reasonable effort must be
made to achieve compliance without violating the Pefmit.
The options available to regain compliance are choices the grower and integrator !Hake for
their particular situation. Common responses are water conservation procedures and with the
weather permitting to apply to their spray fields within the permit guidelines. Another option
would be to pump and haul the waste to another legal site. Culling of animals from the
confinement houses and depopulation help to reduce the waste flow into the lagoons and thus the
volume that has to be removed to achieve compliance. Modification of the CAWMP to
incorporate more land or better -suited crops can also be done with the help of a technical
specialist. This plan of action items to take can be implemented singularly or in combination
depending on the severity of each situation.
Since this event started staff has met with you and representatives of the company you
contract grow for in order that all parties cooperate to protect the environment and assist your
farm in regaining compliance. It is the opinion of this office that restocking should not take place
until compliance has been achieved. Delayed restocking is a point that has been agreed upon by
both the producer and the integrator in this case. Mr. Reason currently has seven confinement
barns of his twenty that are empty.
LVMWI
N. C. Division of Water Quality 225 Green Street Fayetteville, North Carolina 28301-5043 [phone] Fax (910) 48"707 Customer Senice
1-877-623-6748

Mr. Ray Reason
01-20-04
Page 2
This office encourages you to continue to expand your waste handling options by all means
that are in accordance with your permit. While events of the past cannot be changed this office
recognizes your recent efforts and looks ahead to working with you in the future.
If you have any questions concerning this matter, please do not hesitate to contact either Mr.
Larry Baxley, Environmental Specialist, or myself at [phone].
S r ,
j�
Paul E. Rawls
Regional Water Quality Supervisor
W 117, 117
cc: Keith Larick - Compliance Group
Chris Bordeaux - Bladen Co. NRCS
Trent Allen — SWC, FRO
Central Files - Raleigh
N. C. Division of Water Quality 225 Green Sweet Fayetteville, North Carolina 28301-5043 [phone] Fax [phone]
t. A
II
NDENUR
Customer Service
1-877-623-6748

Michael F. Easley, Governor
Division of Water Quality
Coleen H. Sullins. Deputy Director
Division of Water Quality
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. E. Director
April 5, 2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Reason
PO Box 2201
Elizabethtown, NC 28337
Subject: Wettable Acres Determination Request
Administrative Code 15A NCAC 2H .0217
Reason Farms l & 2
Facility No. 9-16
Bladen County
Dear Mr. Reason:
The Fayetteville Regional Office of the Division of Water Quality has been working with you
for some time addressing ongoing compliance issues. Part of this effort has focused on file
review of items essential for proper waste management on Reason # 1 & Reason # 2. The events
of the past five months suggest that there are items that need -clarification. One of these is the
Wettable Acres Determination completed in 1999 by Technical Specialist, Sonya Barber.
Another is the fulfilling of the conditional certification of the farm.
By this letter we ask that you provide a copy of the Wettable Acres Determination and all
supporting documentation used to prepare it for your farm. The additional information would be,
but not necessarily limited to, the wettable acres worksheets and the maps expressing all of the
fields/pulls associated with the CAWMP. The conditional certification would be a signed form
indicating that the cover crop as required by the CAWMP was established by 6-30-98. We ask
that you submit this information by April 16, 2004 to the Fayetteville Regional Office.
This office encourages you to continue to follow your CAWMP in accordance with your
permit.
AV
iN�1�Et�
N. C. Division of Water Quality 225 Grcen Street Fayetteville, North Carolina 28301-5043 [phone] Fax [phone] Customer Service
1-877-623-6748

Mr. Reason
04-5-04
Page 2
If you have any questions concerning this matter, please do not hesitate to contact either Mr.
Larry Baxley, Environmental Specialist, or myself at [phone].
Sincere] ,
Paul E. Rawls
Regional Water Quality Supervisor
PR/lb
cc: Keith Larick - Compliance Group
Chris Bordeaux - Bladen Co. NRCS
Trent Allen — SWC, FRO
Central Files - Raleigh
NCOM
N. C. Division of Water Quality 225 Green Street Fayetteville, North Carolina 28301-5043 [phone] Fax [phone] Customer Service
1-877-623-6748

14 A TF
Michael F. Easley, Governor
�p
Division of Water Quality
Coleen H. Sullins. Deputy Director
y
Division of Water Quality
r
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek. P. E. Director
May 24, 2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Reason
PO Box 2201
Elizabethtown, NC 28337
Subject: Farm Status and Update
Reason Farms l & 2
Facility No. 9-16
Bladen County
Dear Mr. Reason.
In an effort to be proactive and address issues before they develop into larger more complex
problems the Fayetteville Office of the Division of Water Quality would like to remind you that
we are now entering hurricane season. The National Weather Service is expecting a very active
season this year and we ask that you bear that in mind as you make decisions for managing
Reason Farms l & 2 and it's lagoons this year.
Staff members conducted a farm visit on May 14, 2004 and the lagoon levels were recorded
on that date. Lagoon number 1 was at 14" and number two was at 22". Review of office
information shows no current Plan of Action (POA) has been received for lagoon #1. in addition -
the winter annual needed to be removed from the fields in order to promote growth of the Coastal
Bermuda. This is important due to the limited acres with a suitably established Coastal Bermuda
covering.
The Fayetteville Regional Office has been informed your farm is for sale but please be
advised all elements of the Permit and CAWMP must still be followed. Further, it is our
understanding that you have chosen to continue to keep your farm depopulated as part of your
plan to bring your farm back into compliance. This office encourages you to continue to manage
your waste handling system by all necessary means to once again bring your farm into full
compliance.
Based on the above, please provide your plan of action to bring lagoon #1 (Reason Farm # 1)
into compliance. Also, please provide this office with your strategy to build sufficient freeboard
to as adequately as possible maintain compliance if or when eastern North Carolina is subject to
hurricane like storm events this year. Please provide this requested information by June 15•
2004. 9-��
N. C. Division of Water Quality 225 Green Street Fayetteville, North Carolina 28301-5043 [phone] Fax [phone] Customer Service
1-877-623-6748

Mr. Ray Reason
5-24-04
Page 2
If you have any questions concerning this matter, please do not hesitate to contact either Mr.
Larry Baxley, Environmental Specialist, or myself at [phone].
Sincere
aul . Rawls
Regional Water Quality Supervisor
PR/lb
cc: Keith Larick - Compliance Group
Chris Bordeaux - Bladen Co. NRCS
Trent Allen — SWC, FRO
Central Files - Raleigh
t`�r=rat
N. C. Division of Water Quality 225 Green Street Fayetteville, North Carolina 2 83 01-5043 (9 i 0) 486-1541 Fax [phone] Customer Service
1-877-623-6748

0
April 5, 2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Ms. Ray Reason
• PO Box 2201
Elizabethtown, NC 28337
Michael V Easley, Governor
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
William G. Ross Jr.., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. E. Director
Subject: Wettable Acres Determination Request
Administrative Code l 5A NCAC 2H .0217
Reason Farms 1 & 2
Facility No. 9-16
Bladen County
Dear Mr. Reason:
The Fayetteville Regional Office of the Division of Water Quality has been working with you
for some time addressing ongoing compliance issues. Part of this effort has focused on file
review of items essential for proper waste management on Reason # 1 & Reason # 2. The events
of the past five months suggest that there are items that need clarification. One of these is the
Wettable Acres Determination completed in 1999 by Technical Specialist, Sonya Barber.
Another is the fulfilling of the conditional certification of the farm.
By this letter we ask that you provide a copy of the Wettable Acres Determination and all
supporting documentation used to prepare it for your farm. The additional information would be,
but not necessarily limited to, the wettable acres worksheets and the maps expressing all of the
fields/pulls associated with the CAWMP. The conditional certification would be a signed form
indicating that the cover crop as required by the CAWMP was established by 6-30-98. We ask
that you submit this information by April 16, 2004 to the Fayetteville Regional Office.
This office encourages you to continue to follow your CAWMP in accordance with your
permit_
N. C. Division of Water Quality 225 Green Street Fayetteville, North Carolina 28301-5043 [phone] Fax [phone]
�CE3Ehtt
Customer Service
1477423-6748
tk

Mr. Reason
04-5-04
Page 2
If you have any questions concerning this matter, please do not hesitate to contact either Mr.
Larry Baxley, Environmental Specialist, or myself at [phone].
Sincerel ,
Paul E. Rawls
Regional Water Quality Supervisor
PR/lb
cc: Keith Larick - Compliance Group
Chris Bordeaux - Bladen Co. NRCS
Trent Allen T SWC, FRO
Central Files - Raleigh
N. C. Division of Water Quality 225 Green Street Fayetteville, North Carolina 28301-5043 [phone] Fax [phone]
SNA
f4CDEf
Customer Service
1-877-623-6748

--.. of wArE9
�0 pG
fiy 7
o �
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
April 7, 2005
CERTIFIED MAIL — 7002 2410 0003 0273 1378
RETURN RECEIPT REQUESTED
Mr. Ray Reason
PO Box 2201
Elizabethtown, NC 28337
SUBJECT: Final Notice
Request for Payment of Civil Penalty
Farm # 9-16
Bladen County
File No. PC 04-013
Dear Mr. Reason:
Alan W. Klimek, P.E. Director
Division of Water Quality
Your immediate attention to this matter is required. On January 28, 2005, the Division of
Water Quality (DWQ) assessed a civil penalty against you in the amount of $4,621.14, including
$621.14 in investigative costs, for violations of your NPDES Permit. DWQ has the certified
mail green card that shows that the civil penalty assessment was received by Roy Tickle on
January 31, 2005.
In that letter, you were notified that you had three options available to you within thirty (30)
days according to North Carolina General Statute 143-215.6A. You could pay the penalty, you
could request remission of the penalty, or you could file a contested case petition with the Office
of Administrative Hearings. As of April 7, 2005, you have not done any of those three things.
Therefore, by state law, the full amount of the penalty is immediately due
and payable. This Ietter serves as final notice that DWQ will refer your case to the
North Carolina Attorney General's Office unless payment is received within 10 days
of your receipt of this notice. If necessary, the Attorney General's Office will file a
case allainst you in the Superior Court of Bladen Counly to collect the penalty.
rCaro t
ura�r
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636
Internet: httt):A2o.enr.state.nc.us 2729 Capital Boulevard Raleigh, NC 27604
An Equal opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper
Phone [phone] Customer Servicc
Fax [phone]
Fax [phone]

Ray Reason
April 7, 2005
Page 2
Please send the payment within ten calendar days to:
Mr. Steve Lewis
DWQ
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
RECEIVE[)
D
APR 11 2W5
vaR-FAVETTEUUE 0
FFa
If you would like a receipt that your payment was received, please send it via certified mail.
If you have any questions, please contact Steve Lewis at [phone] or Keith Larick at (919)
715-6185.
Sincerely,
Steve Lewis
Animal Feeding Operations Unit
cc:a'�ardt Fayetteville Regional Office
Larry Baxley, FRO
File # PC 04-013
APS Central Files

o`'Z� w a r�9Qc
r
7
.� > -i
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
April 7, 2005
CERTIFIED MAIL — 7002 2410 0003 0273 1378
RETURN RECEIPT REQUESTED
Mr. Ray Reason
PO Box 2201
Elizabethtown, NC 28337
SUBJECT: Final Notice
Request for Payment of Civil Penalty
Farm # 9-16
Bladen County
File No. PC 04-013
Dear Mr. Reason:
Alan W. Klimek, P.E. Director
Division of Water Quality
Your immediate attention to this matter is required. On January 28, 2005, the Division of
Water Quality (DWQ) assessed a civil penalty against you in the amount of $4,621,14, including
$621-14 in investigative costs, f6r violations of your NPDES Permit. DWQ has the certified
mail green card that shows that the civil penalty assessment was received by Roy Tickle on
January 31, 2005.
In that letter, you were notified that you had three options available to you within thirty (30)
days according to North Carolina General Statute 143-215.6A. You could pay the penalty, you
could request remission of the penalty, or you could file a contested case petition with the Office
of Administrative Hearings. As of April 7, 2005, you have not done any of those three things.
Therefore, by state law, the full amount of the penalty is immediately due
and payable. This letter serves as final notice that DWQ will refer your case to the
North Carolina Attorney General's Office unless payment is received within 10 days
of your receipt of this notice. If necessary, the Attorney General's Office will file a
case against you in the Superior Court of Bladen County to collect the penalty.
1 rr, Caro ina
,J�atura117Y
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636
Internet: httn:l/h2o.enr-5tate.nc.us 2728 Capital Boulevard Raleigh, NC 27604
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper
Phone [phone] Customer Service
Fax [phone]
Fax [phone]

RAY Reason
April 7, 2005
Page 2
Please send the payment within ten calendar days to: RECE
IVED
Mr. Steve Lewis I APR 11 20M
DWQ D9�t-farFrr�yt�ra+�u ol��
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
If you would like a receipt that your payment was received, please send it via certified mail.
If you have any questions, please contact Steve Lewis at [phone] or Keith Larick at (919)
715-6185.
Sincerely,
Steve Lewis
Animal Feeding Operations Unit
cc: Art Barnhardt, Fayetteville Regional Office
y B x1ey;FRO
File # PC 04-013
APS Central Files

[Fwd: update Reason]
Subject: [Fwd: update Reason]
Date: Tue, 23 Mar 2004 08:40:10 -0500
From: Paul Rawls <Paul.Rawls@ncmai].net>
To: larry baxley <[e-mail]>
Please put all of Geno's a -mails in the appropriate facility file.
Thanks
Subject: update Reason
Date: Fri, 19 Mar 2004 05:57:42 -0800 (PST)
From: Geno Kennedy <agrimentservices@yahoo_com>
To: Larry Baxley <[e-mail]>
CC: Paul Rawls <[e-mail]>
Larry,
I just wanted to give you some documented information on Ray Reason. 1 was there 3/11/04 and both
lagoons were at 13". The farm has only four houses left with animals out of 20 that is an 80%
depopopulation, the other houses are scheduled to go out soon and no re -pop is planned. He has just
started spraying selectively on the Bermuda which has full PAN available however, he is working with
Rick Morris on some improvements to his spray fields.
With Kind Regards,
Ronnie "Geno" Kennedy Jr.
President of Operations
Agriment Services, Inc.
PO Box 1096 Beulaville, NC 28518
Office [phone] Fax [phone] Mobile [phone]
www.agrimentservices.com
Do you Yahoo!?
Yahoo! Mail - More reliable, more storage, less seam
of 1 3/23/2004 12:05 PM

O� \NA Michael F. Easley, Governor
_O� 9pG Division of Water Quality
Coleen N. Sullins. Deputy Director
y Division of Water Quality
William G. Ross Jr., Secretary
vNorth Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. E. Director
October 20, 2003
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Reason
PO Box 2201
Elizabethtown, NC 28337
Subject: NOTICE OF VIOLATION/NOTICE OF INTENT
Administrative Code 15A NCAC 2H .0217
Reason Farms 1 & 2
Facility No. 9-16
Bladen County
• Dear Mr. Reason,
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 2H .0217 and /or NCGS 143 —
215.1, you have been found to be in violation of your Permit.
Recently, staff from the Fayetteville Regional Office of the Division of Water Quality
conducted a review of the records you submitted for your permitted, NCA209016, swine farm
located on Rosendale in Bladen County. During that review, it was noted that the freeboard level
for lagoon # 2 for the time period of December 23, 2002 until January 13, 2003 was within the
storm storage freeboard at 18 inches. On April 14,2003 records indicate a lagoon level in lagoon
#2 of 12 inches, thus entering the structural portion of the freeboard. The Fayetteville Regional
Office has no notification from your facility for this time period. Please be advised that your
NPDES Permit states " the Permittee shall report by telephone to the appropriate Regional Office
as soon as possible, but in no case more than 24 hours following first knowledge of the
occurrence of failure to maintain storage capacity in a lagoon storage greater than or equal to that
required in Condition V(3) of this NPDES Permit". Condition V(3) states " The maximum waste
level in lagoons/storage ponds shall not exceed that specified in the GAWP. 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 l foot of structural
freeboard"_ This failure to report is a violation of a permit condition and will result in
enforcement action being recommended.
N. C. Division of Water Quality 225 Green Street Fayetteville. North Carolina 28301-5043 [phone] Fax [phone] Customer Service
1-877-623-6748

Mr. Reason
10-20-03
Page 2
The Division of Water Quality requests that the following items be addressed:
1. Report as required liquid lagoon levels in the storm or structural freeboard to the
appropriate Regional Office of the Division of Water Quality within 24 hours of
discovery. Follow up with the appropriate Plan of Action in a timely manner.
2. Follow all provisions of your COC, General Permit, and CAWMP.
3. Manage the liquid level of the lagoon at your facility.to the "stop pump" marker to
provide the needed free storage volume to more effectively cope with wet or chronic
rainfall conditions.
4. Correspondence and providing requested information such as records are permit
conditions and should be addressed in a timely manner. Please be more attentive to
these matters in the future as they are a necessary part of conducting your business.
Failure to comply with the above condition(s) may result in the facility losing its General
Permit and being required to obtain an individual non -discharge permit for the facility.
Please be advised that this notice does not prevent the Division of Water Quality from
taking enforcement actions for this violation or any past or future violation. You are hereby
notified that based on the above information, the Division of Water Quality is considering
forwarding a recommendation to the Director for consideration of enforcement for this
violation. Furthermore, the Division of Water Quality has the authority to levy a civil
penalty of not more than $25,000.00 per day per violation.
If you have an explanation for this violation that you wish to present to this office, please
forward a detailed explanation, in writing, of the events noted and why you feel that this office
should not proceed with recommendation for enforcement. This office on or before November
10, 2003 should receive this response. Information provided to this office will be reviewed and, if
enforcement is still deemed appropriate, your explanation will be forwarded to the Director with
the enforcement package for his consideration.
tea►
N. C. division of Water Quality 225 Green Street Fayetteville. North Carolina 28301-5043 [phone] Fax [phone] Customer Senrice
- 1-877-623-6748

Mr.Reason
10-20-03
Page 3
If you have any questions concerning this matter, please do not hesitate to contact either Mr.
Larry Baxley, Environmental Specialist, or myself at [phone].
cerely,
Paul . Rawls
Regional Water Quality Supervisor
PR/lb
cc: Keith Larick - Compliance Group
Chris Bordeaux - Bladen Co. NRCS
Trent Allen — SWC, FRO
Central Files - Raleigh
N. C. Division of Water Quality 225 Green Street FayetteN2lle, North Carolina 28301-5043 [phone] Fax (910) 48"707
Grp
NMrENUR
Customer service
1-877-623-6748

ADI1END[}1V.2A+RAY REASON
' Subject: ADDENDUM 2A RAY REASON
Date: Thu, 18 Dec 2003 14:11:1 1 -0800 (PST)
From: Geno Kennedy <agrimentservices a yahoo.com>
To: Larry Baxley <[e-mail]>
CC: Paul Rawls <[e-mail]>
Larry,
This is just a un-signed copy for your files.
With Kind Regards,
Ronnie "Geno" Kennedy Jr.
President of Operations
Agriment Services, Inc.
PO Box 1096 Beulaville, NC 28518
Office [phone] Fax [phone] Mobile [phone]
www.agrimentser-vices.com
Do you Yahoo!?
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Name: RAY REASON NARRF.doc
Type: WINWORD File (application/msword)
MRAYREASONNARR I'.doc Encoding: base64
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Download Status: Not downloaded with message
1 of] 12/19/2003 8:58 AM

a
REVISED ADDENDUM TO WASTE UTILIZATION PLAN 2a: 12118103
FACILITY NUMBER 09-16
FARM NAME: REASON FARMS
OWNER NAME: RAY REASON
DESIGN CAPACITY- 15040 FEEDER TO FINISH
HYDRAULIC LOADING OF ADDITIONAL EMERGENCY
APPLICA TION FIELDS
TRACT
FIELD
SOIL TYPE
HYDRAULIC LOADING
3064
3A
GBA/NOB
.51n/hr
.96 in/per/event
4809
4B
NOA
.5in/hr
.96 in/per/event
4809
5A
NOA
.5in/hr
.96 in/per/event
4809
6,7B
NOA
.5in/hr
.96 in/per/event
4809
6,7A
LN
.5in/hr
.96 in/per/event
4809
1,8A
GBA
.5in/hr
.96 in/per/event
4809
4A '
GBA
.51n/hr
.96 in/per/event
4809
unl.
GBA/LN
.5inft
.96 in/per/event
PER THIS ADDENDUM TO THE WASTE UTILIZATION PLAN
PLEASE INCORPORATE THE AGRONOMIC RATES AND WINDOWS
OF THE PLAN OF ACTION DATED 12/9/03 (UPDATED) 1/5/04 AS
PART OF THE CURRENT WASTE UTILIZATION PLAN. THE
WINTER ANNUAL RATE OF 100 LBS IS GENERIC IN REGARDS TO
SOIL TYPE AND THE APPLICATION WINDOWS ARE ENCLOSED
FOR EACH FIELD AND CROP. THE PLAN OF ACTION REVEALS
THE AGRONOMIC RATES AND WINDOWS FOR EACH CROP.
ALL FIELDS MUST MEET MONITORING AND REPORTING
REQUIREMENTS WHEN USED. MR. REASON PLANS TO APPLY HIS
SWINE WASTE IN ACCORDANCE WITH HIS SPECIFIC WASTE
ANALYSIS NOT TO EXCEED THE HYDRAULIC LOADING OF THE
SOILS.
1 /5/04 1 /5/04
RONNIE G. KENNEDY JR. RAY REASON
TECHNICAL SPECIALIST OWNER/OPERATOR

II. TOTAL POUNDS OF PAN STORED WITHIN STRUCTURAL FREEBOARD AND/OR 25 YR.124
HR. STORM STORAGE ELEVATIONS IN ALL WASTE
STRUCTURES FOR FACILITY
1.
Structure I D: Reason 1
line m =
814.9 lb PAN
2.
Structure ID: Reason 2
line m =
3044.5 lb PAN
3.
Structure ID:
line m =
lb PAN
4.
Structure ID:
line m =
lb PAN
5.
Structure ID:
line m =
lb PAN
6_
Structure ID:
line m =
lb PAN
n.lines 1+2+3+4+5+6= 3859.4lbPAN
Ill. TOTAL PAN BALANCE REMAINING FOR AVAILABLE CROPS DURING 30 DAY DRAW DOWN
PERIOD. DO NOT LIST FIELDS TO WHICH PAN CANNOT BE APPLIED DURING THIS 30 DAY PERIOD_
o. tract #
p_ field #
q. crop
r_ acres
s. remaining IRR
2 PAN balance
(Iblacre)
t. TOTAL PAN
BALANCE FOR
FIELD (Ibs.)
column r x s
u_ application window'
4809
1,8a
winter annual
4.50
100.00
450.0
sep 1 - a r 15th
4809
6,7a
winter annual
2.50
100.00
250.0
sep, 1 - a r 15th
4809
6,7b
winter annual
1.50
100.00
150.0
sep 1 - a r 15th
4809
5a
winter annual
2.00
100.00
200.0
sep 1 - a r 15th
4809
pull 7W
small grain overseed
6.15
41.00
252.2
oct 1 - mar 31
4809
pull 1
small grain overseed
4.49
50.00
224.5
oct 1 - mar 31
4809
pull 2
small grain overseed
5.21
50.00
260.5
oct 1 - mar 31
3064
3a
winter annual
6.00
100.00
600.0
sep 1 - a r 15th
4809
4a
winter annual
2.50
100.00
250.0
sep 1 - a r 15th
4809
4b
winter annual
1.50
100.00
150.0
sep 1 - a r 15th
4809
UN1
winter annual
10.00
100.00
1000.0
se 1 - a r 15th
'State current crop ending application date or next crop application beginning date for available
receiving crops during 30 day draw down period.
v. Total PAN available for all fields (sum of column t) = 3787.2 lb. PAN
IV. FACILITY'S PoA OVERALL PAN BALANCE
PoA (30 Day) 2121100

w. Total PAN to be land applied (line n from section II) = 3859.4 lb. PAN
x. Crop's remaining PAN balance (line v from section 111) = 3787.2 lb. PAN
y. Overall PAN balance (w - x) = 72.3 lb. PAN
Line y must show as a deficit. If line y does not show as a deficit, list course of action here including pump and
haul, depopulation, herd reduction, etc. For pump & haul and herd reduction options, recalculate new PAN
based on new information_ If new fields are to be included as an option for lowering lagoon level, add these
fields to the PAN balance table and recalculate the overall PAN balance. If animal waste is to be hauled to
another permitted facility, provide information regarding the herd population and lagoon freeboard levels at the
This Plan of Action is written based on Wettable acreage calculations vs. actual field measurements performed
by the Farm Service Agency. Areas of application are denoted and have an irr-2 form for each area that will
receive waste. It will be necessary to gain approximatetly 10 - 12 more acres of cropland unless nitrogen
samples, that have been taken come back less than what is shown in this POA. This could lower the pan and
require less land than what is predicted. The method of application will be with tanker/aerway systems
whichever can be utilized the easiest in the locations permitted to receive waste. The pulls denoted in the plan
could utilize an irrigation reel to apply the pan left if conditions permit. Otherwise they will be applied with
alternative aerway/tanker equipment. Mr. Reason has a considerable amount of land designated as non -wet by
the Farm Service Agency. He may, depending on the variables in this POA, begin the clearing process to gain
more land. (UN1 IS ESTIMATED AT APPROXIMATELY 10 ACRES ACTUAL SURVEY MAY BE NEEDED TO
DETERMINE TRUE ACREAGE) A waste utilization plan ADDENDUM is attached also for review_ Waste will be
applied agronomically and hydraulically as weather permits.
Ronnie G. Kennedy Jr.
1 /5/04
PoA (30 Day) 2/21 /00

PLAN OF ACTION (PoA) FOR HIGH FREEBOARD AT ANIMAL FACILITIES
30 DAY DRAW DOWN PERIOD
I. TOTAL PAN TO BE LAND APPLIED PER WASTE STRUCTURE
1. Structure Namelidentifier (ID): Reason 1 Fac # 09-16 12/9/2003
2. Current liquid volume in 25 yr_I24 hr. storm storage & structural freeboard
a. current liquid level according to marker
b. designed 25 yr.124 hr. storm & structural freeboard
c. line b - line a (inches in red zone) =
d. top of dike surface area according to design
(area at below structural freeboard elevation)
e, line c112 x line d x 7.48 gallonslft3
3. Projected volume of waste liquid produced during draw down period
17.0 inches
19.0 inches
20 inches
173236 K2
215968 gallons
f. temporary storage period according to structural design 180 days
g. volume of waste produced according to structural design 210994.7 ft3
h. current herd # 4800 certified herd #1 6400
actual waste produced = current herd # x line g =
certified herd #
i. volume of wash water according to structural design
j. excess rainfall over evaporation according to design
k. (lines h + i + j) x 7.48 x 30 days/line f=
4. Total PAN to be land applied during draw down period
I. current waste analysis dated 9/16/2003
m. ((lines e + k)11000) x line I =
REPEAT SECTION I FOR EACH WASTE STRUCTURE ON SITE.
(Click on the next Structure tab shown below)
158246 ft3
0 ft3
104270.$ ft3
327271 gallons
1.50 Ibs11000 gal.
814.9 lbs. PAN
PoA (30 Day) 2/21 /00

PLAN OF ACTION (POA) FOR HIGH FREEBOARD AT ANIMAL FACILITIES
30 DAY DRAW DOWN PERIOD
I. TOTAL PAN TO BE LAND APPLIED PER WASTE STRUCTURE
1. Structure Name/Identifier (ID): Reason 2 Fac # 09-16 12/9/2003
2. Current liquid volume in 25 yr.124 hr. storm storage & structural freeboard
a. current liquid level according to marker 12A inches
b. designed 25 yr./24 hr. storm & structural freeboard 19.0 inches
c. line b - line a (inches in red zone) = 7.0 inches
d. top of dike surface area according to design
(area at below structural freeboard elevation) I 212926 ft2
e. line c112 x line d x 7.48 gallons/ft3 929067 gallons
3. Projected volume of waste liquid produced during draw down period
f_ temporary storage period according to structural design 180 days
g. volume of waste produced according to structural design 284842 ft3
h. current herd # 7200 certified herd #1 8640
actual waste produced = current herd # x line g =
certified herd #
i. volume of wash water according to structural design
j. excess rainfall over evaporation according to design
k. (lines h + i + j) x 7.48 x 30 days/line f=
4. Total PAN to be land applied during draw down period
1. current waste analysis dated 1 9/16/2003
m. ((lines e + k)/1000) x line I =
REPEAT SECTION I FOR EACH WASTE STRUCTURE ON SITE.
(Click on the next Structure tab shown below)
237368 ft3
0 ft3
127458 ft3
454817 gallons
2.20 Ibs/1000 gal.
3044.5 lbs. PAN
PoA (30 Day) 2121/00

REVISED ADDENDUM TO WASTE UTILIZATION PLAN 2a: 12118103
FACILITY NUMBER 09-16
FARM NAME: REASON FARMS
OWNER NAME: RAY REASON
DESIGN CAPACITY: 15040 FEEDER TO FINISH
HYDRAULIC LOADING OF ADDITIONAL EMERGENCY
APPLICATION FIELDS
TRACT
FIELD
SOIL TYPE
HYDRAULIC LOADING
3064
3A -
GBA/NOB
.5in/hr
.96 in/per/event
4809
4B
NOA
.5in/hr
.96 in/per/event
4809
SA
NOA
.5in/hr
.96 in/per/event
4809
6,7B
NOA
.51n/hr
.96 in/per/event
4809
6,7A
LN
.5in/hr
.96 in/per/event
4809
I,8A
GBA
.5irAr
.96 in/per/event
4809
4A
GBA
.5in/hr
.96 in/per/event
ALL FIELDS MUST MEET MONITORING AND REPORTING
REQUIREMENTS WHEN USED. MR. REASON PLANS TO APPLY HIS
SWINE WASTE IN ACCORDANCE WITH HIS SPECIFIC WASTE
ANALYSIS NOT TO EXCEED THE HYDRAULIC LOADING OF THE
SOILS.
12/18/03
RONNIE G. KENNEDY JR.
TECHNICAL SPECIALIST
12/ I8/03
RAY REASON
O WN ER/OPERATOR

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State of North Carolina
Department of Environment,
Health and Natural Resources
Fayetteville Regional Office
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Mr. Ray Reason
P. O. Box 2201
Elizabethtown, N. C. 28337
e��
[DEHNR
DIVISION OF WATER QUALITY
June 17, 1997
SUBJECT: NOTICE OF DEFICIENCY
Reason One Swine Farm
Facility No. 09-16
Bladen County
Dear Mr. Reason:
On June 12, 1997, staff from the Fayetteville Regional Office of the Division of Water Quality
conducted an inspection at Reason One Swine Farm to determine compliance with their certified
animal waste management plan (CAWMP). At the time of the investigation our staff confirmed that
the facility had not planted a crop (bermuda grass). In addition, the lagoon had no grass cover to
prevent erosion and no waste analysis had been collected or analyzed. The 55 acres of waste
application spray field were cleared, however; large piles of trees were still remaining in the spray
field area and had not been prepared for planting. The waste application records were not completed
because the waste analysis was not available. The Division of Water Quality may proceed with
additional actions against Reason One Swine Farm, unless the following items are addressed:
1. immediately plant the required crop (coastal bermuda) per your Certified Animal Waste
Management Plan (CAWMP) in the 55 acre spray application field to allow for the application of
waste at agronomic rates.
2. Immediately collect a waste analysis sample to comply with the CAWMP and so adequate
records may be maintained of the waste application on the crop.
3. Consult with a technical specialist with the Agriculture Extension Office knowledgeable in
grass cover for erosion control.
Wachovia Building, Suite 714, Fayetteville ��y. FAX [phone]
North Carolina 28301-5043 N�� C An Equal Opportunity Affirmative Action Employer
Voice 910-486-1541 50% recycled/10% post -consumer paper

Page 2
Mr. Ray Reason
June 17, 1997
Nothing in this letter should be taken as absolving this facility of the responsibility and liability
of any violations that have or may result from these deficiencies.
Please provide a written response to this office on or before July 6, 1997, regarding
corrective actions taken or planned. if you have any questions concerning this matter, please do not
hesitate to contact me at [phone].
Sincerely,
Robert Heath
Environmental Specialist
KTS/RFH
cc: Operations Branch
Central Files
Audrey Oxendine, FRO, NC DSWC
Sam Warren, Bladen County MRCS

�. ivorin t.arouna
1. Department of Environment and Natural Resources
Division of Water Quality
Fayetteville Regional Office
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Kerr T. Stevens, Director
June 12, 2001
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Reason
P.O. Box 2201
Elizabethtown, NC 28337
Subject_ NOTICE OF VIOLATIONIN011E QF INTENT
Administrative Code 15A NCAC 2H .0217
Reason One Swine Farm
Facility No.09-16
Permit No. AWS 090016
Bladen County
Dear Mr. Reason:
NCDENR
You are hereby notified that, having been permitted to have a non discharge permit for the
subject animal waste disposal system pursuant to 1 5A NCAC 2H .0217, you have been found to
be in violation of your 2H _0217 Permit.
On May 23, 2001, staff from the Fayetteville Regional Office of the Division of Water Quality
conducted a routine inspection of your swine farm located off SR1708 (Rosendale Road) in
Bladen County. The inspection revealed that the waste application fields had a small gI ain cover
crop at maturity which was required to be removed prior to seeding. -In addition, the inspection
revealed that the bermuda crop was non-existent as a result of shading by the wheat, oats, and
rye in most fields. Field # 3 had no cover crop established and the north 2/3 of the field had no
bermuda grass established. Also, a prior discharge was identified adjacent to the lagoon dike
where wastewater was ponded in an overgrown area as the result of a leak at the Z- pipe_
225 GREEN STREET- SUITE 7I41 SYSTEL BUILDTNG / FAYETTEVILLE, NC 28301. 043
PRONE [phone] FAX [phone] W Whir'-ENR.STATE.NC US/EN
AN EQUAL OPPORTUNITY /AFFIRMATIVEACTION EMPLOYER -50%RECYCLED/10% POSTCONSUMER PAPER
DENR TOLL FREE HOTLINE: [phone]

r
Mr. Ray Reason.
Page 2
June 12, 2001
The Division of Water Quality requests that the following items be addressed:
1. Immediately cut and remove the small grain overseed crop from all bermuda fields.
2. Immediately establish the required summer crop (coastal bermuda) for waste application per
your CAWMI' on all fields.
Contact a irrigation specialist to repair the malfunctioning Z-pipe to prevent future
discharges.
Failure to comply with, the above conditions may result in the facility losing its General Permit
and being required to obtain an individual non discharge permit for the facility -Please be advised
that this notice does not prevent the Division of Water Quality from taking enforcement actions
for this violation or any past or future violation.
You are hereby notified that based on the above information the Fayetteville Regional Office
of the Division of Water Quality is considering forwarding a recommendation to the Director for
consideration of enforcement for this violation. Furthermore, the Division of Water Quality has
the authority to levy a civil penalty of not more than $25,000.00 per day per violation.
If you have an explanation for these violations that you wish to present to this office
pleaseforward a detailed explanation, in writing, of the events noted and why you feel that this
office should not proceed with recommendations fo enforcement. This response should be
received by this office on or before June 26, 2001.
If you have any questions concerning this matter, please do not hesitate to contact either
myself or Mr. Robert Heath, Environmental Specialist, at [phone].
Sincerely,
v
Pawl E. Rawls
Regional Water Quality Supervisor
RFH/ bh/PER
cc: Sonya Avant- Compliance Group
Sam Warren - Bladen Co. MRCS
Trent Allen - DSWC Fayetteville Office
Central Files - Raleigh

4 Division of Water Quality -
Q`Drvrsron of Soil and Water Conservation
ws Q OthCU.
gency
Type of Visit ® Compliance Inspection O Operation Review O Lagoon Evaluation
Reason for Visit 0 Routine O Complaint O Follow up Q Emergency Notification Q Other ❑ Denied Access
Facility Number jDateorvisit:
F-
EPermitted. ®Certified .3 Conditionally Certified (] Registered
Farm Name: .............Rk.cro
Owner Name:
Time: Slid Printed on: 7/21/2000
Q Not Operational Q Below Threshold
Date Last Operated or Above Threshold: ..........
County:
..:�......: ...............................
Phone No-. C 9 �7� — O Z 2 9
...................................................
FacilityContact: ..........1�.......,eCRllr!�.......................Title:................................................................ Phone Nu:...................................................
57
Mailing Address: ........ -.......r....{1R.......
Onsite Representative: So".� I3�y�z��.c Integrator: ....!lOI�I•�.a,�gytQ.rJ�
.......I.. ....... ..........
Certified Operator: �?)............................................................ Operator Certification Number:..........................................
Location "of Farm:
❑ Swine ❑ Poultry ❑ Cattle ❑ Horse Latitude • 4 66 Longitude • 6 44
De_si
tn
a;
Desgn Current
Desrggrt ' . .
airratiiotn
S'vine
._e
Po elation.
CateP9
. Population
Wean to Feeder
❑ Layer
❑ Dairy
Feeder to Finish
d
❑ Non -Layer
❑Non -Dairy
Farrow to Wean
Farrow to Feeder
❑ Other
:F Farrow to Finish
Total Design C*jkkd y
gar` Gilts
Boars
Total'SSL°W '
z xt er`of_L$gooiis .
2.
❑ Subsurface Drains Present 110
Lagoon Area
10 Spray Field Area
Holldmg i?oads / SolidtlTraps
❑ No Liquid Waste Management System
Discharges & Stream Impacts
1. Is any discharge observed from any part of the operation?
❑ Yes No
Discharge originated at: Lagoon ❑ Spray Field ❑ Other
a. If discharge is observed, was the cunvevance man-made'? ❑ Yes ,� No
h. If discharge is observed, did it reach Water of the State'? (If yes, notify DWQ) ❑Yes No
c. If discharge is observed. what is the estimated flow in gal/min?
d. Dees discharge bypass a lagoon system? (If yes, notify DWQ) ❑ Yes Mo
2. Is there evidence of past discharge from any part of the operation? WfYes ❑ No
3. Were there any adverse impacts or potential adverse impacts to the Waters of the State other than from a discharge? ❑ YesNo
Waste Collection & Treatment
4. Is storage capacity (freeboard plus storm storage) less than adequate?
Structure I Structure 2 Structure 3
Identifier:...........�%l,Z.//......................1 �..J/..
Freeboard (inches):
5100
❑ Spillway ❑ Yes PWNo
Structure 4 Structure 5 Structure 6
Continued on back

Facility Number: D — % Date of Inspection Printed on: 7/21/2000
• 5- Are there any immediate threats to the integrity of any of the structures observed? (ic/ trees, severe erosion, ❑ Yes 15No
seepage, etc.)
6. Are there structures on -site which are not properly addressed and/or managed through a waste management or
closure plan? ❑ Yes �fNo
(If any of questions 4-6 was answered yes, and the situation poses an
immediate public health or environmental threat, notify DWQ)
7. Do any of the structures need maintenance/improvement? J"Yes ❑ No
8. Does any part of the waste management system other than waste structures require maintenance/improvement? ElYes PC No
9. Do any stuctures lack adequate, gauged markers with required maximum and minimum liquid level
elevation markings? ❑ Yes KNo
Waste Application
10.
Are there any buffers that need maintenance/improvement?
❑ Yes
�<No
11.
Is there evidence of over application? ❑ Excessive Ponding ❑ PAN ❑ Hydraulic Overload
❑ Yes
R1 No
12.
Crop type
13.
Do the receiving crops differ with those designated in the Certified Animal Waste Management Plan (CAWMP)?
❑ Yes
JgNo
14.
a) Does the facility lack adequate acreage for land application?
❑ Yes
ANo
b) Does the facility need a wettable acre determination?
❑ Yes
KNo
c) This facility is pended for a wettable acre determination?
❑ Yes
Jallo
15.
Does the receiving crop need improvement?
AYes
❑ No
16.
Is there a lack of adequate waste application equipment?
❑ Yes
'ONO
Reauired Records & Documents
17.
Fail to have Certificate of Coverage & General Permit readily available?
❑ Yes No
18.
Does the facility fail to have all components of the Certified Animal Waste Management Plan readily available?
(ie/ WUP, checklists, design, maps, etc.)
❑ Yes
❑ No
19.
Does record keeping need improvement? (ie/ irrigation, freeboard, waste analysis & soil sample reports)
❑ Yes
❑ No
20.
Is facility not in compliance with any applicable setback criteria in effect at the time of design?
❑ Yes
X'No
21.
Did the facility fail to have a actively certified operator in charge?
XYes
❑ No
22.
Fail to notify regional DWQ of emergency situations as required by General Permit?
(ie/ discharge, freeboard problems, over application)
❑ Yes
❑ No
23.
Did Reviewer/Inspector fail to discuss reviewlinspection with on -site representative?
❑ Yes
No
24.
Does facility require a follow-up visit by same agency?
❑ Yes
® No
25. Were any additional problems noted which cause noncompliance of the Certified AWMP? ❑ Yes ® No
0; viola igzjs;e� defe�er�cies wire ie tee dt�r}ng #ttis;v...... will . . . . .Rio f. th�r
correspondence: atbvulk this visit.::..::::::.... ' :::..::: .
#) Explain any YES answers "and/or any_ i aeon
2 . A4S&"A/4W_ (,eJ.4! D v,.J 6ri6/� of" �iv% d/.GC'�/��iYGEs a
&s .9 / ,� d.✓ �e, / .:a .� /.r r4,�.�•} 'wife. w
PPS �'✓ �,i ,.���>�i
®,c1 aw G
e /1ki
ReviewerAnspector Name
Reviewer/Inspector Signature:
Date: .�%1,��Of 5/00

Facility Number: C> Date of inspection 6/ Printed on: 7/21/2000
Odor Issues
26_ Does the discharge pipe from the confinement building to the storage pond or lagoon fail to discharge at/or below Yes []No
liquid level of lagoon or storage pond with no agitation?
27. Are there any dead animals not disposed of properly within 24 hours? ❑ Yes figNo
28. Is there any evidence of wind drift during land application? (i.e. residue on neighboring vegetation, asphalt, ❑ Yes ONo
roads, building structure, and/or public property)
29. Is the land application spray system intake not located near the liquid surface of the lagoon? ❑ Yes JSD4o
30. Were any major maintenance problems with the ventilation fan(s) noted? (i.e. broken fan belts, missing or
or broken fan blade(s), inoperable shutters, etc.) ❑ Yes KNo
31. Do the animals feed storage bins fail to have appropriate cover? ❑ Yes R-No
32. Do the flush tanks lack a submerged fill pipe or a permanent/temporary cover? Yes ❑ No
_Additional Comments and/or Drawings:'.'
5100

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Kerr T. Stevens, Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
RAY REASON
PO Box 2201
ELIZABETHTOwN NC 28337
Dear Ray Reason:
LTIMEMA,
IT 0 0
�A41A
M sk
h ''� ? 1 V LU1NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FEB 12 2001 February 1, 2001
Subject: Notice of Violation and Revocation for Nonpayment
Reason Farms
Permit Number: AWS090016
Bladen County
In accordance with North Carolina General Statute 143-215.10G, all animal operations who receive an animal
waste management system permit will be charged in each year of the term an annual permit fee. Annual permit fees are
billed following the issuance of the permit and then annually thereafter on the anniversary of that date. Your animal waste
management system permit was issued on 11/17/1997.
Your annual permit fee for the period of 11/17/2000 - 1 1/16/2001 is $300.00. Your payment was due 1/1012001.
Because this fee was not fully paid within 30 days after being billed, this fetter initiates action to revoke the subject permit.
pursuant to 15 NCAC 2H .0205 (c) (4). and G_S. 143-215.1 (b) (3).
Effective 60 days from receipt of this notice, the subject permit is hereby revoked unless the required Annual
Animal Waste Management System Permit fee for your animal operation is received within that time. Operation of an
animal waste management system without a valid permit is a violation of North Carolina General Statute 143-215.1 and is
subject to the assessment of a civil penalty of up to $10,000 per day. Your payment should be sent to:
N.C. Department of Environment and Natural Resources
Division of Water Quality
Budget Office
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
1 f you have any questions, please contact Fran McPherson at [phone] ext. 210.
Sincerely,
Kerr T. Stevens
cc: Non -Discharge Branch Compliance/Enforcement Unit
Fayerteville Regional Office
Bladen County Health Department
Permit File
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled / 10% post -consumer paper

,t /
` NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
FAYETTEVILLE REGIONAL OFFICE
September 8, 2000
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Reason
PO Box 2201
Elizabethtown, NC 28337
Subject: Notice of Violation
Reason Farms
Facility No. 09-16 Permit No. AWS 090016
Bladen County
Dear Mr. Reason:
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 2H
.0217, you have been found to be in violation of your 2H .0217 Permit.
On August 24, 2000, staff from the Fayetteville Regional Office of the
Division of Water Quality performed a routine inspection of the Reason Farms in
Bladen County. During this inspection, it was noted that the crops at both sites
were not adequate to take up the nitrogen produced at these facilities, at
agronomic rates. The Reason One Farm has very little to irrigate on due to the
fact that most of the spray field is covered with weeds and may have shaded out
the bermuda crop completely. The fields at the other farm have been sprigged
with bermuda in the old row crop fields. The portions of this farm that weren't
sprigged were over taken with weeds and do not have a crop that is suitable for
the uptake of nitrogen. The lack of suitable bermuda crop at this site has been an
ongoing problem as noted in all prior inspections.
The Division of Water Quality requests that the following itern(s) be
addressed:
1. Irrigation should be performed on fields which have an adequate and growing
crop established which has a published R.Y.E. value.
2 0 1 0 .
275 GREEN STREET, SUITE 714 / SYSTEL OLD. FAYETTEVI1-LE, NORTH CAROLINA 28301-5043
PHONE 91 O-406-1 541 FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50`+yo RECYCLEO/10% POST -CONSUMER PAPER

I
Mr. Reason
9-8-00
Page 2
Failure to comply with the above conditions may result in the facility losing its General Permit and
being required to obtain an individual non discharge permit for the facility.
` Please be advised that this notice does not prevent the Division of Water Quality from taking
enforcement actions for this violation or any past or future violation. Furthermore, the Division
of Water Quality has the authority to levy a civil penalty of not more than $25,000.00 per day per
violation.
If you have any questions concerning this matter, please do not hesitate to contact either
myself or Mr. John Hasty, Environmental Specialist, at [phone].
Sin ,
a
Paul E. is
Water Quality Regional Supervisor
cc: Sonya Avant -Compliance Group
Sam Warren-Bladen Co. NRCS
Trent Allen-DSWC Fayetteville Office
Glenn Davis -Brown's of Carolina
Central Files -Raleigh

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FAYETTEVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
July 30, 1999
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Ray Reason
P.O. Box 2201
Elizabethtown, NC 28337
SUBJECT: NOTICE OF DEFICIENCY
Reason Farms
Facility No. 09 -16
Bladen County
Dear Mr. Reason:
On June 16,1999, staff from the Fayetteville Regional Office of the Division of Water Quality
conducted a routine inspection of your swine facility located in Bladen County. It was observed that
there were portions of the inside and back slopes of both lagoon dikes that failed to have permanent
vegetation. There was a low area in the front spray field at Reason #2 that contained some standing
storm water. The small spray field at the Reason 41 site also contained some standing storm water
in a low area adjacent to the lagoon. The coastal bermuda fields on both farms were in poor
condition. The coastal bermuda field at the Reason #1 farm had a severe problem with broadleaf
weeds (primarily pigweed) and other grasses. Crabgrass appeared to be the dominant grass in the
majority of the largest spray field at the Reason #2 site.
A review of the farm records indicated that freeboard records were not being maintained
weekly as required by the General Permit originally issued to this facility on November 17, 1997.
Freeboard levels were being recorded, however they were not being recorded weekly. General
Permit condition 111.2 states that "Waste lagoon and storage pond levels shall be recorded weekly
on forms supplied or approved by the DWQ.".
The Division of Water Quality requests that the following items be performed:
1. Establish a grass cover on both the inside and back slopes of lagoon dikes to prevent erosion.
2. Consult with a technical specialist or the local NRCS district for assistance in correcting the low
areas in the waste application fields so that these areas can be utilized for waste application
following the establishment of a crop.
3. Keep weeds and other grasses controlled in the coastal bermuda throughout the current growing
season to allow coastal to spread. Evaluate the coastal at the end of the growing season to
determine if some areas will require resprigging.
4. Immediately begin recording freeboard levels weekly in order to be in compliance with the
General Permit.
225 GREEN STREET, SUITE 714, FAYETTEVILLE, NORTH CAROLINA 28301-5043
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/1 O% POSY -CONSUMER PAPER

Page 2
Reason Farms
July 30,1999
Please notify this office in writing on or before August 25,1999 at the letterhead above as to the actions taken
or proposed to be taken to resolve these deficiencies. Nothing in this letter should be taken as absolving this facility of
the responsibility and liability of any violations that have or may result from these deficiencies. If you have any questions
concerning this matter, please do not hesitate to contact myself at [phone].
Sincerely,
///7 Arz�,�
Jeffery Brown
Environmental Engineer
cc: Sonya Avant - Compliance Group
Sam Warren - Bladen Co. NRCS
Audrey Oxendine - QSWC Fayetteville Office
Central Files - Raleigh
Jimmy Vinson - Brown's of Carolina, Inc.

3 JAMCS B. HUNT J
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FAYETTEVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
July 30,1999
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Ray Reason
P.O. Box 2201
Elizabethtown, NC 28337
SUBJECT. NOTICE OF DEFICIENCY
Reason Fames
Facility No. 09 -16
Bladen County
Dear Mr. Reason:
On June 16,1999, staff from the Fayetteville Regional Office of the Division of Water Quality
conducted a routine inspection of your swine facility located in Bladen County. It was observed that
there were portions of the inside and back slopes of both lagoon dikes that failed to have permanent
vegetation. There was a low area in the front spray field at Reason #2 that contained some standing
storm water. The small spray field at the Reason #1 site also contained some standing storm water
in a low area adjacent to the lagoon. The coastal bermuda fields on both farms were in poor
condition. The coastal bermuda field at the Reason #1 farm had a severe problem with broadleaf
weeds (primarily pigweed) and other grasses. Crabgrass appeared to be the dominant grass in the
majority of the largest spray field at the Reason #2 site.
A review of the farm records indicated that freeboard records were not being maintained
weekly as required by the General Permit originally issued to this facility on November 17,1997.
Freeboard levels were being recorded, however they were not being recorded weekly. General
Permit condition 111.2 states that 'Waste lagoon and storage pond levels shall be recorded weekly
on forms supplied or approved by the DWQ.'.
The Division of Water Quality requests that the following items be performed:
1. Establish a grass cover on both the inside and back slopes of lagoon dikes to prevent erosion.
2. Consult with a technical specialist or the local NRCS district for assistance in correcting the low
areas in the waste application fields so that these areas can be utilized for waste application
following the establishment of a crop.
3. Keep weeds and other grasses controlled in the coastal bermuda throughout the current growing
season to allow coastal to spread. Evaluate the coastal at the end of the growing season to
determine if some areas will require resprigging.
4. Immediately begin recording freeboard levels weekly in order to be in compliance with the
General Permit.
225 GREEN STREET, SUITE 714, FAYETTEVILLE, NORTH CAROLINA 26301 -5048
p1foNE 410-466-1E41 FAX 61 O-486-0707
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER PAPER
MSO

Y ! ' I
r �
Page 2
Reason Farms
July 30, 1999
Please notify this office in writing on or before August 25, 1999 at the letterhead above as to the actions taken
or proposed to be taken to resolve these deficiencies. Nothing in this letter should be taken as absolving this facility of
the responsibility and liability of any violations that have or may result from these deficiencies. If you have any questions
concerning this matter, please do not hesitate to contact myself at [phone].
Sincerely,
ljo�, Arw-,�
Jeffery Brown
Environmental Engineer
cc: Sonya Avant - Compliance Group
Sam Warren - Bladen Co. MRCS
Audrey Oxendine - DSWC Fayetteville Office
Central Files - Raleigh
Jimmy Vinson - Brown's of Carolina, Inc.

iI.
k,
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FAYETrEVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
June 26, 1998
Mr. Ray Reason
P.O. Box 2201
Elizabethtown, NC 28337
Subject: Notice of Recommendation for Enforcement
Reason One Swine Facility
Facility No. 09-16
Bladen Co.
Dear Mr. Reason.
This letter is to notify you that the Fayetteville Regional Office of the Division
of Water Quality is considering sending a recommendation for enforcement action to
the director of the Division of Water Quality. The recommendation concerns the
violation by the Reason One Swine Farm of North Carolina General Statute 143-
215.1 for discharging wastewater to the surface waters of the State from a non
discharge facility on February 11, 1998.
if you have an explanation for this violation that you wish to present, please
respond to this office on or before June 30, 1998. Your explanation will be reviewed
and if an enfor"mer:t boa is still d+eerned ep-ropriate, ;our explanation will be
forwarded to the Director with the enforcement package for his consideration.
225 GREEN STREET, SUITE 714. FAYETTEVILLE, NORTH CAROLINA 28301-5043
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/I 0% POST -CONSUMER PAPER

If you have any questions concerning this matter, please contact me at [phone].
Sincerely,
t5l L-1� I.�
fIkerr T. Stevens
Regional Supervisor
cc: Sue Homewood - Compliance Group
Central Files

L' Via'
NCDENR
`-'-- JAMES B. HUNT JR.- •'*
GOVERNOR
�_ •, , .7e
SECRETARY
-_ 4:1� �.'��e::�i`.a�=gym•:-. _ _
X
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FAYETTEVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
June 26, 1999
I I ov 11313 Mts"MITI Tom 73 v M1
W. Ray Reason
P.O. Box 2201
Elizabethtown, NC 28337
Subject: Notice of Recommendation for Enforcement
Reason One Swine Facility
Facility No. 09-16
Bladen Co.
Dear Mr. Reason:
This letter is to notify you that the Fayetteville Regional Office of the Division
of Water Quality is considering sending a recommendation for enforcement action to
the director of the Division of Water Quality. The recommendation concerns the
violation by the Reason One Swine Farm of North Carolina General Statute 143-
215.1 for discharging wastewater to the surface waters of the State from a non
discharge facility on February 11, 1998.
If you have an explanation for this violation that you wish to present, please
respond to this office on or before June 30, 1998. Your explanation will be reviewed
and if an enforcement action is still deemed appropriate, your explanation will be .
forwarded to the Director with the enforcement package for his consideration.
225 GREEN STREET, SUITE 714, FAYETTEVILLE, NORTH CAROLINA 28301-5043
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - SO% RECYCLED/10% POST -CONSUMER PAPER

t
If you have any questions concerning this matter, please contact me at [phone].
Sincerely,
4, H-
Akerr r, Stevens
Regional Supervisor
cc: Sue Homewood - Compliance Group
Central Files
ti

Ki
State`of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
Ray Reason
Reason Farms
PO Box 2201
Elizabethtown NC 28337
Dear Ray Reason:
6ffl?W,A
RECEIVE04-16
.lift i 7 199$ CDENR
FA lm-'T-T ,*%F-:, E,.i=
�., NC RTH CARO iMEPAr�r�E�; C r
EtwiRONENT AN N R ESe�U cEnrj i5 r 1!
June 26, 1998
FI
U U L 2 1998 N1
WASHING;ON REGIONAL OFFICE
Subject: Reissuance of Certificate of Coverage
No.AWS090016
Reason Farms
Swine Waste Collection, Treatment, Storage and
Application System
Bladen County
The Division of Water Quality modified the Swine Waste Operation General Permit originally issued to
this facility on November 17, 1997. In accordance with the issuance of the revised General Permit, we
are forwarding this Certificate of Coverage (COC) to Ray Reason, authorizing the operation of the
subject animal waste collection, treatment, storage and land application system in accordance with
General Permit AWG100000. This approval shall consist of the operation of this system including, but
not limited to, the management of animal waste from the Reason Farms, located in Bladen County, with
an animal capacity of no greater than 15040 Feeder to Finish and the application to land as specified in
the Certified Animal Waste Management Plan (CAWMP).
The COC shall be effective from the date of issuance until April 30, 2003, and shall hereby void
COC No AWS090016 dated November 17, 1997. The COC shall hereby incorporate by reference any
specific conditions of the previous COC issued to this facility. The purpose of this COC is to allow
coverage under the revised General Permit. Please review the revised General Permit (enclosed) and pay
particular attention to Condition II.10 regarding tree removal from lagoon embankments, Condition I1I.1
regarding inspection frequency of the waste treatment, storage and collection system and Condition III.6
regarding notification requirements for system failures, spills and emergencies. Pursuant to this COC,
you are authorized and required to operate the system in conformity with the conditions and limitations
as specified in the General Permit, the facility's CAWMP, and this COC, with no discharge of wastes to
surface waters. An adequate system for collecting and maintaining the required monitoring data and
operational information must be established for this farm. Any increase in waste production greater than
the certified design capacity or increase in number of stocked animals above the number authorized by
this COC will require a modification to the CAWMP and this COC and shall be completed prior to
actual increase in either wastewater flow or number of animals.
Please be advised that any violation of the terms and conditions specified in this COC, the
General Permit or the CAWMP may result in the revocation of this COC, or penalties in accordance
with NCGS 143-215.6A through 143-215.6C including civil penalties, criminal penalties, and injunctive
relief.
R.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recyded110% post -consumer paper

Certificate of Coverage AWS090016
Reason Farms
Page 2
!'
Upon notification by the Division of this COC's expiration, you shall apply for its renewal. This
request shall be made within 30 days of notification by the Division.
This COC is not automatically transferable. A name/ownership change application must be
submitted to the DWQ prior to a name change or change in ownership.
If any parts, requirements, or limitations contained in this COC are unacceptable, you have the
right to apply for an individual non -discharge permit by contacting the engineer listed below for
information on this process. Unless such a request is made within 30 days, this COC shall be final and
binding.
The subject farm is located in the Fayetteville Regional Office. The Regional Office Water
Quality Staff may be reached at [phone]. If you need additional information concerning this
COC or the General -Permit, please contact J. R. Joshi at [phone] ext. 363.
Sincerely,
A. Preston Howard, Jr
cc: (Certificate of Coverage only for all cc's)
Bladen County Health Department
Fayetteville Regional Office, Water Quality Section
Bladen County Soil and Water Conservation District
Permit File
14
, P.E.

y
c•
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
May 10, 1999
Mr. Ray Reason; Jr.
Reason One Swine Farm
P.O. Box 2201
Elizabethtown, NC 28337
kv�.�T'j
40
Ar4j 0
D E N R
REC€li/Ep
MAY 2 i ig"
I�AY,ErMVILLE
F011 OFFXt
SUBJECT: Acknowledgment receipt letter
Civil Penalty Assessment of Violation
Case # DD 98-011
Bladen County
Farm # 09-16
Dear Mr. Reason:
This letter is to acknowledge receipt of your check No. 100116 in the amount of $4,460.69
received from Reason one Swine Farm on May 10, 1999.
This payment satisfies in full in the amount of $4,460.69, levied against Mr. Ray Reason
and this case is closed. Payment of these penalties in no way precludes further action by this
Division for future violations of the State's environmental laws.
If you have any questions please call Shannon Langley at [phone], extension
581.
Sincere
Je f Poupart, Supervise
Non -Discharge Branch
(
S11/tw
cc: Fayetteville Regional Office
Enforcement Files DD 98-01 I
Central Files
Mary Dee Carraway-AG's Office
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

I
5y5y11
1
h
Division of water Quality
July 27, 1998
MEMORANDUM
To: Colleen Sullins
Non Discharge Permit Section
From: Robert Heath Aq
Environmental Specialist, FRO
TLru: Stephen Bari
acting Regional S r
SUBJECT. Enforcement Package
Reason Swine Farm
Facility 09- 16
Please find attached a fast track enforcement package pertaining to the discharge of
animal waste at the subject facility. The subject facility has required numerous inspections
due to their failure to comply with the certified animal waste management plan. The
owner has not accepted the certified mail sent to him on two different occasions.
If you require additional information or clarification, please advice.
Attachment

1 _ Date of Inspection(s): Febru= I l a 1998
3. Name of Owner Of Property: Rai Ems= (C= of Deed attaclh4
4. Name of Operator. MI. ft Roson
5. Address: P.Q. Box 3301
Elizabethtmm NC_28337
6. Phone Number: (910) 872 ;4229
7. Description of Facility Location, Map excerpt attached.
Travel fr'omElizabethtown Qn-SR 1700 ftgr&r Road) to SR 1708 Mmm ale Road]_ turn
left go (.Q Clarks Crossroads_ continue on SR 1708, facility is located =rQximately 1 mile
on deht.—
!: •: « \ . �•.: 1 • •�_t%_� • 4 �!: Sill!_ .L _►� 5 -. • hit • 4 __P. a
' Date of a . • i! ' &ciliv w• _J • '.• 1• IJ • -? in " ! !. Vi 2---ViJ!! • 1
10. Has the facility registered with DWQ? YES NO_
If yes, date of registration 1118/95
11. Does the facility have an approved Animal Waste Management Plan YES NO_
Is one required? YES. NO_
Date Approved: October 14- 1997
12. Has this facility received a CAFO Designation? YES_ NOX
If yes, date issued:
13. Type of Operation:

• + :, • ' �A;: t t t ell : 1 ' 1 zK! + M. + _ t R -
1 + 1 ' • y�l + l
15. Length of time animals have been, are, or will be stabled, or confined and fed or maintained
in any 12 month period. Twelve (,12months._
16. Are crops, pasture, or post harvest residues sustained in the normal growing season over any
portion of the lot or facility? Yes. the farm wu desigaWh - - . nately 120 ams of
crop land on which to waste —The - ceried waste management -plan calls for a
combination of berm daagrass,�corn and soybeans and ryr, gmss to be grown on vario:
sites.Annroximately 40 acres are located gnlhg Reason One site where nQ crone
established.
18. Description of other animal operations in immediate vicinity and proximity to same or
other surface waters: It was noted that_nQ olber swine farms are in close proximity to this
faWiV.
19_ Proximity of facility to neighboring houses, wells, etc.: It was noted that a residence was
located approdmate]x 2000 feet from the north pQcUon of the spry field.
20. Approximate depth of ground water table in the area of the facility or discharge: unknown
21- Proximity of facility to surface waters: Horseshoe swamp bisects the F"Iy and the
Mayfidds are located. on both sido of the, surfip& waters.
22. Animal waste discharged. J J,

23. Are pollutants discharged in the waters of the State? YES
If so, how? After a DWQ aerial survalance flight on 2/10/98, Water Quality staff
responded by performingan inapection of the Rmon One spLay fields at a roximatel
1350 hours on 2/11198. Waste apRlication had been conducted on the previous morning
of 2/10/98 and was occurring on_2/11198 at the time of the inspection Waste was runnin g
off the fields into nearby streams and waterways during the application event. (See
attached photos).
24. Do or have discharges occurred in response to a storm event less severe than the 25-
year,24 hour storm? Yes. A discharge occurred_ from this facility on or about February
11.1998_ It is also important to note that the lagoon did not have more than a few (9)
inches of freeboard approximately two weeks prior to the discharge and- had a total of
20 inches at the time of the discharge. Also no 25 year -24 hour storms had occurred
recently, however. several inches of rain fell between the time of the lagoon_inspection on
January 23, 1928 and the discharge.
25. What is the degree and extent of harm to the natural resources of the State, to public
health,or to private property resulting from the violation?: The discharge has caused, the
introduction of nutrients into the receiving surface waters, that will cause or add to the
possibili . of algal blooms and accelerated eutrophication-of the slow moving waters of
the receiving stream. Also, samples taken indicate elevated fecal coliform levels
downstream of the facility.
Sample results:
Sample Location (2117/97)
1. Field discharge run-o-1D#98WE2838
2. Upstream-ID#98 V U2840
3. Downstream -ID _ 8WD2841
4. Downstream ID98WE2839 _
Coliform. Fecal / 100m]
1900
<1
207
40
***PLEASE SEE ATTACHED COMPLETE LAB RESULTS
AND PHOTOGRAPHS FOR MORE INFORMATION***
There are no known public health issues at this time. Waste discharges of this nature
may, based ,on comments from Dr. M.A. Mixson. North Carolina Department o
Agriculture. Veterinary Division transport swine diseases if conditions are suitable,.

26. What is the duration and gravity of the violation?: As mentioned previously. —the
farm was observed by DWQ_.personnel from a airplane to be_ discharging waste
during the morning hours of 2/10/98. Furthermore, it was clear that_the traveler gun had
been positioned at a point on the field with the highest elevation and allowed to operate
with out engaging the_ traveler. Consequently, run-off probably occurred almost
immediately due to_ the slope and the saturated condition of the field. Based on this
information, it can be surmised that waste had probably been dischargine for the duration
of the irrigation eventThe waste was discharging from the _field into the adjacent woodland
and entering a road ditch --and then traveling approximately _1500—feet into Horseshoe
Swamp. The waste observed being applied the previous day was still ponding in the
adjacent woodsland and sprayfield and running off into Horseshoe Swam.It is estimated
that approximately 1.5 million gallons of waste were a lied during this two week ppriod
with the majority resulting in runoff due to the saturated conditions and the lack of a crop
in the waste a lication fields.
27. Water Quality Assessment: At the time of -the inspection, the discharge flow. was
significant at the points it reached the wetlands to Horseshoe Swam —making up an
estimated 10% of the total flow in the swamp. Where the waste was discharged into the
stream, the waste flow represented approximately 5 % of the total flow of the stream.
28. What is the cost of rectifying the damage?: The writer observed no areas that cleanup
activities would be recommended. Any cleanup would cause adverse impacts to nearby
wetlands. There has been no re ort gf downstream impacts outside the area of the
investigation.
29. What is the amount of money saved by noncompliance?: Based on observations made
during the investigations, the cost was significantly decreased by applying the waste to an
unsuitable waste application field due to the potential saving to possibly truck the waste
to an acceptable site or possibly be a required to depopulate due to the previous lagoon level
on Januaa 23, 1998 of 9 inches.
30. Was the violation committed willfully or intentionally?:
YES X NO_
Explain: The irri gation equipment o erators should have been more careful in how much
and where the waste was being_applied and observed the system after startup to determine
that the equipment was operating in accordance with the CAWMP:The farm had —not
notified the DWQ that the lagoon level had risen into the emergencyemergengy storage voIume..-Tbe
operator should have observed that the previous days application had „reach surface waters
and --- notified the DWQ and should not have relocated the irrigation equipment and
continued to discharge waste into the waters of the state.
31. What is the prior record of the violator in complying or failing to comply with programs
over which Environmental Management Commission has regulatory authority? Reason Opp
Farm was reizistered with the DWQ on JanuaKy 181995. The facili1y received a Notice

of Deficiency -(NODA_on June 17. 1997 for failure to establish the required crops in the 55
acres of spray field and for no grass cover on the lagoon banks. and no waste analysis
samples. A follow up inspection was conducted on Janua 23 1998 to determine
compliance and at that time no crops -had -been established as required by the CAWMP and
requested in the NOD of June 17. 1997. A NOV was issued on_January 28, 1998 for
failure to correct the problems identified in the NOD -of June 17, 1997 and -for a higlk
freeboard violation.
32. What is the cost to the State for the enforcement procedures?:
Regional Costs are as follows:
Photo, film and developing: $ 6.00
Mileage: $0.20 per mile for 100 miles: $ 20.00
Fecal Coliform ($22.00 per sample) * 4: $ 88.00
Robert Heath @ $ 17.62Ihr
2 hours - Drive Time
$
35.24
1.5 hours - Investigation
$
26.43
5 hours - Report Development
$
88.10
hours 8.5 total
$
149.77
John Hasty @ $17.621hr
2 hours - Drive Time
$
35.24
1.5 hours - Investigation
$
26.43
hours -3.5 total
$
61.67
Kerr T. Stevens - 1 hour (Supervisory Review) $ 35.05
Central Office Review $ 100.00
Total $ 557.93
33. Type or general nature of business: Swine. Feeder to Finish Operation
34. What is the violator's degree of cooperation or recalcitrance:
Mr. Ray Reason has not cooperated to correct_ the problems identified during any
inspections to prevent further discharges from happening in the future. He has requested
and received conditional certification from the _technical specialist employed by the
integrator rather than correct _thg problems._ To date, no corrections have been made to
alleviate the lack of waste application fields available for this site to include the installation
of an irrigation system or the establishment of crops
35. Are there any Mitigating Circumstances?: NO

c. Damage Yes _ No -2L (Based on observations at the time of the investigation)
If YES, include report from Wildlife Resources Commission.
37. Include a copy of any Designation letter signed by the Ditecto .
38. Recommendations Made to Owner/Operator:
ifields,
2_ Take immediate action to prevent any future discharge ofwaste.
I- Contact MRCS to obtain technical assi.=ce if necessary
• Recommendationsi fAction:
Enforcement
-! nay _ +
40. Other Comments- In summuL it is the opinion of flus —writer that the discharge
fields dwing a rain event and the failure to Rage the traveling gun. Ihe cxistini2 fields =
satu ed tQ i=dated with water -six months out of the yem. This would seem to gafl for
modification of t' CAVVW.

k- • 154- -615 796•
us PoS stal ervice
( Receipt for Certified Mail
W Iasurarlce Coverage Frov*ea.
M not use for Intema#onat Mai! See reverse
ay Reason
'` Wox °f2201
TITz"areli�� NC
28337
S
.32
c6I�Ea Fee
1.35
s��� .
P&;t W Oeivery Fee
Re1um Receipl5howiep 10
Whom �aerlYel�d
1.10
p
iiELlfIS.�^ go"i� b
Raw
Dah, d Adtreaee� Adtrrss
TOTAL Postage 8 Fees
$
2.77
Poanrlals< or Gate
1/2B/96
- NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FAYET'rEVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
January 28, 1998
9JED�AII�
RN RECEIPT REQUESTED
ty Reason
Box 2201
Elizabethtown, NC 28337
Subject: Notice of Violation
Administrative Code 15A NCAC 2H .0217
Reason One Swine Farm
09-16
Bladen County
Dear Mr. Reason:
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 2H .0217, you have been found to be in violation of your 2H
.0217 Permit.
On January 23, 1998, staff from the Fayetteville Regional Office of the
Division of Water Quality conducted a follow-up inspection of your swine
farm located off SR1708 (Rosendale Road) in Bladen County to comfirm
that all prior deficiencies had been corrected. The inspection revealed that
no winter crop (small grain) was established, the lagoon dikes did not have a
suitable cover grass, and the lagoon did not have the required freeboard.
The Division of Water Quality requests that the following items be
addressed:
1. Immediately establish a suitable winter crop for waste application.
225 GREEN STREET, SUITE 714. FAYETTEVILLE, NORTH CAROLINA 20301-5043
PNONE 910-466-1541 FAX 010-48E-0707
AM EQUAL OPPORTI7NITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER PAPER

- - SENDER: - eeroip 9 ■ 0ontpalso wish to revalue stun
- lene t endror 2 tot adtifiliormt ee
S . catnawa ftm 3. sa, end Ab. follo0fig %Mces (tor an
' •Print yow name end eddmu an Ow nvem al #6 farm t+o tat hwe cart rtxwn Vft extra W):
+ ato ym
ch tA form to the f 0V ofthe rneltpbm. w ao the asdi N spam don not 1. n Addressee's Address
e pwrm-
&Wrft@IRdWMR6qWRA1qUM&MrOnft MBPOoe bwow the wade rwrtwc 2. ❑ Restricted Delivery t
■The Flown PAco t vAu show to whom the arb* was deWered ettd the dare
chwmad. COMM postratster for tee.
3. Argde Addressed to: 4a. Amide Number t
P 154 615 796
Mir, Ray Re anon Mr RayPO Box 2201 Reason 4b. Service Type #
© Realstered ® Certified
page 2 Elizabethtown NC 28337 0 Expnm Map p Insured 5
7anuarY 28,1998
M Rehrm Reo* for tr amhand w fl ODD
x. Lower the lagoon leVe 7. Date Delivery 3
soon as weather p� 5. Aeaehred By, (Print Name) resseo Address (Only N requested
fse it paid)
Please be advised that t1 !1 S. Signatur A resew gent) -
enforcement actions for this P. )( �
of Water Qugity has the au '2 Ps Form 3811, Dos&vr 1994 Domestic Retum Receipt
violation. - - - -.._.. - . -.. _ ._ 1 �� l s, " -.a f
en res once to this office on or before February this,tter, please do
Please provide a watt p uestions concerning alist, >st (910) 486-
en or pianneel• If You have any Environmental Specs
corrective actions � or Mr• Robert Heath,
not hesitate to contact either myself
1541.
sing*,
KOT T. Stevens
R4enal Supervisor
cc: Sue Homewood - Compliance Group
Sam `Marren d led D5W F yo"eviile office
NRS
Audrey Oxen
Central Files - Raleigh

.�- - P -1 4-14 3 5 2-2
is Postal Sarvk*
`Necelpt for Certified Mail
140 Insurance Coverage Provide& V.- r
Jo not use forinterrlabonal Mall Ses "'= - NORTH C:AROLINA DEPARTMENTOF
y�R;-
iizaDetntown
- - _ - - On February 11, 1998, staff from the Fayetteville Regional Office of
►.: _:: T` = =� ~ - the Division of Water Quality conducted a follow-up inspection of your
- swine farm located off SRI708 (Rosendale Road) in Bladen County. The
purpose of this inspection was to determine if a discharge of swine waste had
l occurred on February 10, 1998 as observed during a fly over by the DWQ
staff. The inspection revealed that the irrigation equipment was setup in a
field with no cover crop and was operating resulting in a discharge of swine
waste to a unnamed tributary of Elkton Swamp. In addition, the inspection
revealed that the irrigation gun cart was not engaged (traveling), the fields
were saturated due to prior rains and the rain storm occurring at the time of
the inspection, the irrigation system had not been installed as required in the
CAWMP, and the lagoon dikes did not have a suitable cover grass.
1I1 -
F. J2S GREEN STREET, SUITE 714, FAYETTEVILLE, NORTH CAROLINA 20301-5043
- PMoNE p10-4es-1541 FA% 010 86-0707
f AN EOUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - 50% REcvcLE0110% POsT-CONSUMER PAPER

0 SENDER: 1 aJV q9MWe e
-o ■ Complete items 7 andlor 2 for additional servioes.
e
. Complete items 3.40, and 4b. following services (for an
• print your n tme and eddrass an ravem of this form so OW vn oan rehan iris extra fee):
■ cardto t= to the from of the rnm'tpisce, of on the back tl space does not I. ❑ Addressee's Address
s
p
■ � Aatwn Receipt Regrreata r on the nmulpkm habw the article number. 2. ❑ Restricted Deilvary
aThs Return Receipt wt9 show to whom the article was daGwred and Ow data
deswrea Consult postmaster for fee.
3. Attide Addressed to: 4a. Article Number
W. Ray Reason
P 154 743 522
Page 2
n
: C
RAY PMASM 4b. 5ervioe Type
February 12, 199$
PO Box 2201 _ _ ❑ Registered ® Certified
t,zabethtcr-m n7 *2L_-_I ❑ ExpressMd ❑ Insured
® Return Receipt for Meralandtse ❑ COD .
"The Division of Water Qui 7. Date of Iivar)
1. Immediately establish a S. Received By: (Print Name] S. � l e�
2. Install the required irrig; e. 5igna dresses a snr
additional waste from tli M X
Ps Form 3811, De tuber 1994 U Dor
3. Contact a drainage expert for assistance in improving the drainability of the waste
application fields adjacent to the Reason 1 facility where the discharges occurred.
4. Contact an expert in horticulture to assist you in soil preparation and the appropriate cover .
grass for the lagoon banks.
Please be advised that this notice does not prevent the Division of Water Quality from taking
enforcement actions for this violation or any past or future violation. Furthermore, the Division
of Water Quality has the authority to levy a civil penalty of not more than $10,000.00 per day per
violation.
Please provide a written response to this office on or before February 26, I998, regarding
corrective actions taken or planned. If you have any questions concerning this matter, please do
not hesitate to contact either myself or Mr. Robert Heath, Environmental Specialist, at (910) 496-
1541.
Sincerely,
L9
Kerr . Stevens
Regional Supervisor
cc: Sue Homewood - Compliance Group
Sam Warren - Bladen Co. MRCS
Audrey Oxendine - DSWC Fayetteville Office
Central Files - Raleigh.
m

_Iwm�
MCDENR.
4
1.
i
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FAYETTI=VILLE REGIONAL OFFECE
DIVISION OF WATER QUALITY
May 27, 1998
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Reason
P.O. Box 2201
Elizabethtown, NC 28337
Subject: Notice of Recommendation for Enforcement
Reason One Swine Facility
-Facility No. 09-16
Bladen County
Dear Mr. Reason:
This letter is to notify you that the
Fayetteville Regional Office of the Division of
Water Quality is considering sending a
recommendation for enforcement action to the
Director of the Division of Water Quality. The
recommendation concerns the violation by the Reason
One Swine Farm of North Carolina General Statute
143-215.1 for discharging wastewater to the surface
waters of the State from a non discharge facility on
February 11, 1998.
If you have an explanation for this violation that
you wish to present, please respond to this office
on or before June 30, 1998. Your explanation will
be reviewed and if an enforcement action is still
deemed appropriate, your explanation will be
forwarded to the Director with the enforcement
package for his consideration.
228 GREEN STREET, SUITE 7 14, FAYETTEVILLE, NDRTN CAROLiNA 28301-5043
PHONE [phone] FA% 910-486-0707
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - E0% RECYCLED/10% POST -CONSUMER PAPER

Mr. Reason
Page 2
May 27, 1998
If you have any questions concerning this matter, please
contact me at [phone].
sincerely,
�i�� �L
4fxer T. S evens
Regional Supervisor
cc: sue Homewood - Compliance Group
Central Files

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Mlt RAY REASON
SIM& 2201
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P° �1 �16
meson
6-29-98
wnEL , NC 28337
Subject: Notice of Recommendation for Enforcement
.
Reason One Swine Facility
Facility No. 09-16
Bladen Co.
Dear Mr. Reason:
This letter is to notify you that the Fayetteville Regional Office of the Division
of Water Quality is considering sending a recommendation for enforcement action to
the director of the Division of Water Quality. The recommendation concerns the
=
violation by the Reason One Swine Farm of North Carolina General Statute 143-
_ _
215.1 for discharging wastewater to the surface waters of the State from a non
discharge facility on February 11, 1999.
If you have an explanation for this violation that you wish to present, please
respond to this office on or before June 30, 1998. Your explanation will be reviewed
and if an enforcement action is still deemed appropriate, your explanation will be
forwarded to the Director with the enforcement package for his consideration
` $
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225 GREEN STREET. 8U1TE 714. FAYETTLVILLE, NORTH CAROLINA 28301-5043
.,- -
FMONE G10-4aG-1541 FAX 510-4e6-07CT
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AN EQUAL OFFORTUNITY /ArrlRMATIVE ACTION EM/LOYER . 50% RECYCLEO/10% FOtT-00N&LPMER rA/!■

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If you have any questions concerning this matter, please contact me at [phone].
Sincerely,
4 Pr.-q
Akerr 7, Stevens
Regional Supervisor
cc: Sue Homewood - Compliance Group
Central Files

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NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FAYETTEVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
May 27, 1998
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Reason
P.O. Box 2201
Elizabethtown, NC 28337
Subject. Notice of Recommendation for Enforcement
Reason One Swine Facility
-Facility No. 09-16
Bladen County
Dear Mr. Reason:
This letter is to notify you that the
Fayetteville Regional Office of the Division of
Water Quality is considering sending a
recommendation for enforcement action to the
Director of the Division of Water Quality. The
recommendation concerns the violation by the Reason
One Swine Farm of North Carolina General Statute
143-215.1 for discharging wastewater to the surface
waters of the State from a non discharge facility on
February 11, 1998.
If you have an explanation for this violation that
you wish to present, please respond to this office
on or before June 30, 1998. Your explanation will
be reviewed and if an enforcement action is still
deemed appropriate, your explanation will be
forwarded to the Director with the enforcement
package for his consideration.
225 GREEN STREET, SUITE 714, FAYETTEVILLE, NORTH CAROLINA 28301-5043
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY! AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLE011 O% POST -CONSUMER PAPER

U
'Id'
Mr. Reason
Page 2
May 27, 1998
If you have any questions concerning this matter, please
contact me at [phone].
cc: Sue Homewood - Compliance Group
Central Files
Sincerely,
[, �+lr�.�,
�RKer T. S evens
Regional Supervisor

RECEIVED
MAR 9 1998
FlF o�1W
F10E
March 3, 1998
Kerr T. Stevens
Regional Supervisor
NCDEHNR-DWQ
225 Green Street, Suite 714
Fayetteville, NC 28301-5043
Dear Mr. Stevens,
This letter is in response to the Notice of Violation dated February 12,1998 regarding Reason
Farms. Coastal bermuda is scheduled to be re -sprigged as soon as possible. The fields are
currently being prepared for sprigging. A waterway will be established to aid in drainage of
surface water and maintained to prevent run-off during irrigation events. In addition, the
irrigation specialist contacted earlier is scheduled to install permanent irrigation pipe. The lagoon
dikes are being reworked for seeding.
The discharge which occurred at this farm was not intentional and precautionary measures are
being taken which will prevent any future discharge. During irrigation on February 11, the engine
on the reel ran out of gas and was not retrieving the gun. The system was not set up to rim
stationary but was not checked in a timely manner by the operator. The operators have been
instructed to check on the equipment regularly and be at the farm during irrigation.
If you have any questions or require more information, please contact me at [phone].
Sincerely,
eb_V
Ray Reason

March 3, 1998
Kerr T. Stevens
Regional Supervisor
NCDEHNR DWQ
225 Green Street, Suite 714
Fayetteville, NC 28301-5043
Dear Mr. Stevens,
This letter is in response to the Notice of Violation dated January 28, I998 regarding Reason
Farms. A winter crop was planted at this farm in December but did not become well established.
Because the planting dates have passed for winter crops, coastal bermuda will be re -sprigged at
this farm as soon as possible. Irrigation events which occurred in February will be credited to the
coastal bermuda crop. To maintain the lagoon at an acceptable level, irrigation pipe will be
installed to connect the two sites and irrigation will continue on land with a suitable crop.
If you have any questions or require more information, please contact me at [phone].
Sincerely,
Ray Reason

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
February 26, 1999
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Ray Reason
PO Box 2201
Elizabethtown NC 28337
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
RECEIVED
ml �'1? 0 1 1999
FAYETTEVILLE
REG. r -F: ;E
Subject: Notice of Violation and Revocation for Nonpayment
Reason Farms
Permit Number: AWS090016
Bladen County
Dear Ray Reason:
In accordance with North Carolina General Statute 143-215.10G, all animal operations who receive an animal
waste management system permit will be charged in each year of the term an annual permit fee. Annual permit fees are
billed following the issuance of the permit and then annually thereafter on the anniversary of that date. Your animal waste
management system permit was issued on 11117/97.
Your annual permit fee for the period of 11/17/99 - 11/16/99 is $200.00_ Your payment was due 1/6/99. Because
this fee was not fully paid within 30 days after being billed, this letter initiates action to revoke the subject permit, pursuant
to 15 NCAC 2H .0205 (c) (4). and G.S. 143-215.1 (b) (3).
Effective 60 days from receipt of this notice, the subject permit is hereby revoked unless the required Annual
Animal Waste Management System Permit fee for your animal operation is received within that time. Operation of an
animal waste management system without a valid permit is a violation of North Carolina General Statute 143-215.1 and is
subject to the assessment of a civil penalty of up to $10,000 per day. Your payment should be sent to:
N.C. Department of Environment and Natural Resources
Division of Water Quality
Budget Office
P.O. Box 29535
Raleigh, North Carolina 27626-0535
If you have any questions, please contact Fran McPherson at [phone] ext. 210.
Sinc
A. Preston Howard, Jr., P.E.
cc: Non -Discharge Branch Compliance/Enforcement Unit
a ,ette�ill`elRegio lnaiOffice�
Bladen County Health Department
Permit File
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled / 10% post -consumer paper

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
October 16, 1998
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Attn: Ray Reason, Jr.
Reason One Swine Farm
P.O. Box 3301
Elizabethtown, NC 28337
Dear Mr. Reason:
/ 0 •
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
ECEVVED
OCT 2 7 1996
FYE77E 11,! L 1 !=
G.D- =" �.:«z
SUBJECT: Assessment of Civil
Penalties for Violation(s)
G.S 143-215.1
Bladen County
Farm # 09-16
File No. DD 98-011
This letter transmits notice of a civil penalty assessed against Murphy Family Farms in
the amount of $4,460.49 including $460.69in investigative costs. Attached is a copy of the
assessment document explaining this penalty.
This action was taken under the authority vested in me by delegation provided by the
Secretary of the Department of Environment and Natural Resources. Any continuing violation(s)
may be the subject of a new enforcement action, including an additional penalty.
Within thirty days of receipt of this notice, you must do one of the following:
Submit payment of the penalty:
Payment should be made directly to the order of the Department of
Environment and Natural Resources (do not include waiver form).
Payment of the penalty will not foreclose further enforcement action for
any continuing or new violation(s).
Please submit payment to the attention of:
Ms. Coleen Sullins
Water Quality Section Chief
Division of Water Quality
P.O. Box 29535
Raleigh, North Carolina 27626-0535
OR
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

2. Submit a written request for remission or mitigation including a
detailed justification for such request:
A request for remission or mitigation is limited to consideration of the
reasonableness of the amount of the penalty and is not the proper procedure
for contesting the accuracy of any of the statements contained in the
assessment letter. Because a remission request forecloses the option of an
administrative hearing, such a request must be accompanied by a waiver of
your right to an administrative hearing and a stipulation that there are no
factual or legal issues in dispute. You must execute and return to this
office the attached waiver and stipulation form and a detailed statement
which you believe establishes whether:
(a) one or more of the civil penalty assessment factors in 'G.S. 143B-
282. 1 (b) were wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting
from the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining
necessary remedial actions.
Please submit this information to the attention of:
Ms. CoIeen Sullins
Water Quality Section Chief/DWQ
P.O. Box 29535
Raleigh, North Carolina 27626-0535
Please note that all information presented in support of a request for
remission must be submitted in writing. The Director of the Division of
Water Quality will review the information during a bimonthly enforcement
conference and inform you of his decision in the matter of the remission
request_ His response will provide details regarding case status and
provision for further appeal to the Environmental Management
Commision's Committee on Civil Penalty Remissions. Please be advised
that the Committee cannot consider information that was not part of the
original remission request considered by the Director and therefore, it is
very important that you prepare a complete and thorough statement in
support of your request for remission.
OR
3. Submit a written request for an administrative hearing:
If you wish to contest any portion of the civil penalty assessment, you must
request an administrative hearing. This request must be in the form of a written
petition to the Office of Administrative Hearings and must conform to Chapter
150B of the North Carolina General Statutes. You must_

File your original petition with the:
Office of Administrative Hearings
P.O. Drawer 27447
Raleigh, North Carolina 27611-7447
and
Mail or hand -deliver a Copy of the petition to:
Dan McLawhorn
Office of General Counsel
NCDENR
Post Office Box 27687
Raleigh, NC 27611
Failure to exercise one of the options above within thirty days, as evidenced by a
date stamp (not a postmark) indicating when we received your response, will result in
this matter being referred to the Attorney General's Office with a request to initiate a
civil action to collect the penalty. Please be advised that additional assessments may be
levied for future violations which occur after the review period of this assessment.
If you have any questions, please contact Mr_ Shannon Langley at (919) 733-
5083, extension 581.
Sincerely,
A_ Preston Howard, Jr., P.E.
ATTACHMENTS
cc: iRegional:Supervisar W/Y ttachmenFs
Compliance/Enforcement File w/ attachments
.Central Files w/ attachments
Public Information Officer w/attachments

STATE OF NORTH CAROLINA
COUNTY OF
IN THE MATTER OF ASSESSMENT )
OF CIVIL PENALTIES AGAINST )
PERMIT NO. }
ENVIRONMENTAL MANAGEMENT
COMMISSION
WAIVER OF RIGHT TO AN .
ADINIINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO.
.Having been assessed civil penalties totaling for
violation(s) as set forth in the assessment document of the Director of the Division "of Water Quality
dated, _ . the undersigned, desiring to seek remission of the civil
penalties, does hereby waive the right to an administrative hearing in the above -stated matter and
does stipulate that the facts are as alleged in the assessment document.
This the day of , 19
SIGNATURE
ADDRESS
TELEPHONE

STATE OF NORTH CAROLINA
COUNTY OF BLADEN
IN THE MATTER OF
RAY REASON, JR.
FOR MAKING AN OUTLET TO THE
WATERS OF THE STATE OF
NORTH CAROLINA
WITHOUT A PERMIT
NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
File No. DD 98-011
FINDINGS AND DECISION
AND ASSESSMENT OF
CIVIL PENALTIES
}
Acting pursuant to delegation provided by the Secretary of the Department of Environment
and Natural Resources, I, A. Preston Howard, Jr., Director of the Division of Water Quality
(DWQ), make the following:
1. FINDINGS OF FACT:
A. Ray Reason, Jr. operates the Reason One Swine Farm, a swine animal operation in
Sampson County.
B. On February 11, 1998, DWQ staff observed that the application of animal waste onto
saturated spray fields resulted in excessive ponding and runoff to an adjacent
wooded area. Waste runoff from the wooded area was observed entering a ditch.
Waste in the ditch was observed discharging to Horseshoe Swamp, which are Class
"C - Sw" waters of the State within the Lumber River Basin-
C. The Reason One Swine Farm had no valid permit for the above -described activity.
D. The cost to the State of the enforcement procedures in this matter totaled $460.49.
Based upon the above Findings of Fact, I make the following:
I1�ilr�i[rTAILy [r]yCYr]�w:1'.'�
A. Ray Reason, Jr. is a "person" within the meaning of G.S. 143-215.6A pursuant to
G.S. 143-212(4).
B. Horseshoe Swamp constitutes waters of the State within the meaning of G.S. 143-215.1
pursuant to G_S. 143-212(6).

,C. The above -cited discharge constituted making an outlet to waters of the State for
purposes of G.S. I43-215.1(a)(1), for which a permit is required by G.S. 143-215.1.
D. Ray Reason, Jr. may be assessed civil penalties in this matter pursuant to G.S. 143-
215.6A(a)(2), which provides that a civil penalty of not more than ten thousand
dollars ($10,000.00) per violation may be assessed against a person for failing to act
in accordance with.the terms, conditions or requirement of a permit required by G.S.
143-215.1.
E. The State's enforcement costs in this matter may be assessed against Ray Reason, Jr.
pursuant to G.S. 143-215.3(a)(9) and G.S. 143B-282. I (b)(8).
F. The Director, Division of Water Quality, pursuant to delegation provided by the
Secretary of the Department of Environment and Natural Resources, has the
authority to assess civil penalties in this matter.
Based upon the above Findings of Fact and Conclusions of Law, I make the following:
M. DECISION:
Accordingly, Ray Reason, Jr. is hereby assessed a civil penalty of:
$ 14t Q DO . O d for making an outlet to the waters of the State without a
I permit as required by G.S. 143-215.1.
$ 14 t 606. 000 TOTAL CIVIL PENALTY, which is fQ_ percent of the
maximum penalty authorized by G.S. 143-215.6A.
$ 460.49 Enforcement costs
$ TOTAL AMOUNT DUE
As required by G_S. 143-215.6A(c), in determining the amount of the penalty I have considered the
factors listed in G.S.143B-282. I (b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;

(5) The amount of money saved by noncompliance;.
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
(8) The cost to the State of the enforcement procedures.
(Date) Preston Howard, Jr., P.E., Director
Division of Water Quality

fir. •P :�-�.
s4,.JAMES 19. HUNTJR.
,G01/BRNOR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FAYETTEVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
June 26, 1998
Mr. Ray Reason
P.O. Box 2201
Elizabethtown, NC 28337
Subject: Notice of Reconunendation for Enforcement
Reason One Swine Facility
Facility No. 09-16
Bladen Co.
Dear Mr. Reason:
This letter is to notify you that the Fayetteville Regional Office of the Division
of Water Quality is considering sending a recommendation for enforcement action to
the director of the Division of Water Quality. The recommendation concerns the
violation by the Reason One Swine Farm of North Carolina General Statute 143-
215.1 for discharging wastewater to the surface waters of the State from a non
discharge facility on February 11, 1998.
If you have an explanation for this violation that you wish to present, please
respond to this office on or before June 30, 1998. Your explanation will be reviewed
and if an enforcement action is still deemed appropriate, your explanation will be
forwarded to the Director with the enforcement package for his consideration.
22S GREEN STREET, SUITE 714, FAYETTEVILLE, NORTH CAROLINA 29301-5043
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EM FLOYFR - 50% RECYCLED/I 0% POST —CONSUMER PAPER

If you have any questions concerning this matter, please contact me at [phone].
Sincerely,
1� `mil •
err Stevens
Regional Supervisor
cc: Sue Homewood - Compliance Group
Central Files

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FAYETTEVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
May 27, 1998
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Reason
P.Q. Box 2201
Elizabethtown, NC 28337
Subject: Notice of Recommendation for Enforcement
Reason One Swine Facility
Facility No. 09-16
Bladen County
Dear Mr. Reason:
This letter is to notify you that the
Fayetteville Regional Office of the Division of
Water Quality is considering sending a
recommendation for enforcement action to the
Director of the Division of Water Quality. The
recommendation concerns the violation by the Reason
One Swine Farm of North Carolina General Statute
143-215.1 for discharging wastewater to the surface
waters of the State from a non discharge facility on
February 11, 1998_
If you have an explanation for this violation that
you wish to present, please respond to this office
on or before June 30, 1998. Your explanation will
be reviewed and if an enforcement action is still
deemed appropriate, your explanation will be
forwarded to the Director with the enforcement
package for his consideration.
225 GREEN STREET, SUITE 714, FAYETTEVILLE, NORTH CAROLINA 28301-5043
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER PAPER

Mr. Reason
Page 2
May 27, 1998
If you have any questions concerning this matter, please
contact me at [phone].
Sincerely,
OW'L
4er T.S evens
Regional Supervisor
cc: Sue Homewood - Compliance Group
Central Files

State of North Carolina
Department of Environment,
Health and ' Natural Resources
Division of Water Quality
Jaynes B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Ray Reason
P.O. Box 2201
Elizabethtown, NC 28337
Dear Mr. Reasons:
A'41
�EHNF=?L
March 10, 1998 RECEIVED
MAR 1 6 1998
FAYETTEIliLLE
aEG. OFFICE
SUBJECT: Retraction of Civil Penalty
Reason One Swine Farm
Farm #: 09-016
Bladen County
AL 97-016
On September 30, 1997, the Ray Reason was assessed a $500.00 civil penalty
for failing to timely submit a permit application for the subject facility.
Based on correspondence submitted by you and further review by Division of
Water Quality staff it is my decision to retract the civil penalty assessed in case
number AL 97-016 and close this case.
If you have any questions about this letter, please feel free to contact Mr.
Shannon Langley at [phone], extension 581.
Sincerely,
A. Preston Howard, Jr. P.E.
Cc: FayettevfflFRegidMl:Office>
Enforcement File AL 97-016
Central Files
P.O. Box 29536, Raleigh, North Carolina 27626-0535 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50c'o recycled/10% post -consumer paper

IF -\
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1,
,, e, GOVERNOR
` 4 `; v
.s WAYNE 1MCDEVI7T. •+
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"^ NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FAYETTEVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
February 12, 1998
r
Mr. Ray Reason
P.O. Box 2201
Elizabethtown, NC 28337
Subject: Notice of Violation
Administrative Code 15A NCAC 2H .0217
Reason One Swine Farm
09-16
Bladen County
Dear Mr. Reason:
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 2H .0217, you have been found to be in violation of your 2H
.0217 Permit.
On February 11, 1998, staff from the Fayetteville Regional Office of
the Division of Water Quality conducted a follow-up inspection of your
swine farm located off SR1708 (Rosendale Road) in Bladen County. The
purpose of this inspection was to determine if a discharge of swine waste had
occurred on February 10, 1998 as observed during a fly over by the DWQ
staff. The inspection revealed that the irrigation equipment was setup in a
field with no cover crop and was operating resulting in a discharge of swine
waste to a unnamed tributary of Elkton Swamp. In addition, the inspection
revealed that the irrigation gun cart was not engaged (traveling), the fields
were saturated due to prior rains and the rain storm occurring at the time of
the inspection, the irrigation system had not been installed as required in the
CAWMP, and the lagoon dikes did not have a suitable cover grass.
225 GREEN STREET, SUITE 114, FAY ETTEVI LLE, NORTH CAROLINA 283O1-5043
PHONEStO-486-1541 FAX[phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST-CONSU M£R PAPER

Mr. Ray Reason
Page 2
February 12, 1998
The Division of Water Quality requests that the following items be addressed:
1. Immediately establish a suitable summer crop for waste application per your CAWMP.
2. Install the required irrigation system to comply with the CAWMP prior to applying
additional waste from the Reason I facility.
3. Contact a drainage expert for assistance in improving the drainability of the waste
application fields adjacent to the Reason 1 facility where the discharges occurred.
4. Contact an expert in horticulture to assist you in soil preparation and the appropriate cover
grass for the lagoon banks.
Please be advised that this notice does not prevent the Division of Water Quality from taking
enforcement actions for this violation or any past or future violation. Furthermore, the Division
of Water Quality has the authority to levy a civil penalty of not more than $10,000.00 per day per
violation.
Please provide a written response to this office on or before February 26, 1998, regarding
corrective actions taken or planned. If you have any questions concerning this matter, please do
not hesitate to contact either myself or Mr. Robert Heath, Environmental Specialist, at (910) 486-
1541.
Sincerely,
Kerr . Stevens
Regional Supervisor
cc: Sue Homewood - Compliance Group
Sam Warren - Bladen Co. NRCS
Audrey Oxendine - DSWC .Fayetteville Office
Central Files - Raleigh.

_ Yr
i `"•
NCDENR
Fr i
JAMFS B, HUNT JR. E
.,'-GOWRNOR ".
�. • WAYNE MCDMTT ;
�• SECRETARY 4 _ �.a
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NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FAYETTEVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
February 12, 1998
1. P U - I
Mr. Ray Reason
P.O. Box 2201
Elizabethtown, NC 28337
Subject: Notice of Violation
Administrative Code 15A NCAC 2H .0217
Reason One Swine Farm
09-16
Bladen County
IRTFMT_ PT_•—.� 1
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 2H .0217, you have been found to be in violation of your 2H
.0217 Permit.
On February 11, 1998, staff from the Fayetteville Regional Office of
the Division of Water Quality conducted a follow-up inspection of your
swine farm located off SR1708 (Rosendale Road) in Bladen County. The
purpose of this inspection was to determine if a discharge of swine waste had
occurred on February 10, 1998 as observed during a fly over by the DWQ
staff. The inspection revealed that the irrigation equipment was setup in a
field with no cover crop and was operating resulting in a discharge of swine
waste to a unnamed tributary of Elkton Swamp. In addition, the inspection
revealed that the irrigation gun cart was not engaged (traveling), the fields
were saturated due to prior rains and the rain storm occurring at the time of
the inspection, the irrigation system had not been installed as required in the
CAMP, and the lagoon dikes did not have a suitable cover grass.
225 GREEN STREET, SUITE 714, FAYETTEVILLE, NORTH CAROLINA 28301-5043
PHONE [phone] FA% 910-486-0707
AN £DUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER — SO% RECYCLED/I 0% POST -CONSUMER PAPER

Mr. Ray Reason
Page 2
February 12, 1998
The Division of Water Quality requests that the following items be addressed:
1. Immediately establish a suitable summer crop for waste application per your CAWMP.
2. Install the required irrigation system to comply with the CAWMP prior to applying
additional waste from the Reason 1 facility.
3. Contact a drainage expert for assistance in improving the drainability of the waste
application fields adjacent to the Reason 1 facility where the discharges occurred.
4. Contact an expert in horticulture to assist you in soil preparation and the appropriate cover
grass for the lagoon banks.
Please be advised that this notice does not prevent the Division of Water Quality from taping
enforcement actions for this violation or any past or future violation. Furthermore, the Division
of Water Quality has the authority to levy a civil penalty of not more than $10,000.00 per day per
violation.
Please provide a written response to this office on or before February 26, 1998, regarding
corrective actions taken or planned. If you have any questions concerning this matter, please do
not hesitate to contact either myself or Mr. Robert Heath, Environmental Specialist, at (910) 485-
1541.
Sincerely,
J
Kerr . Stevens
Regional Supervisor
cc: Sue Homewood - Compliance Group
Sam Warren - Bladen Co. NRCS
Audrey Oxendine - DSWC Fayetteville Office
Central Files - Raleigh.

t ! _
IVA
1•1
NCDENR_
.. DAMES B. HUNTJ10'_: -'i
rt 'GOVERNOR i--
.:f
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FAYETTEVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
January 28, 1998
CE&TIEIED �; I
Mr. Ray Reason
P.O. Box 2201
Elizabethtown, NC 28337
Subject: Notice of Violation
Administrative Code 15A NCAC 2H .0217
Reason One Swine Farm
09-16
Bladen County
Dear Mr. Reason:
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 2H .0217, you have been found to be in violation of your 2H
.0217 Permit.
On January 23, 1998, staff from the Fayetteville Regional Office of the
Division of Water Quality conducted a follow-up inspection of your swine
farm located off SR1708 (Rosendale Road) in Bladen County to comfirm
that all prior deficiencies had been corrected. The inspection revealed that
no winter crop (small grain) was established, the lagoon dikes did not have a
suitable cover grass, and the lagoon did not have the required freeboard.
The Division of Water Quality requests that the following items be
addressed:
1. Immediately establish a suitable winter crop for waste application.
225 GREEN STREET, SUITE 714, i'AYETTEVILLE, NORTH CAROLINA 28301-5043
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLE0/1 O% POST -CONSUMER PAPER

r-M
Mr. Ray Reason
Page 2
January 28, 1998
2. Lower the lagoon level to the required freeboard on a suitable waste application field as
soon as weather permits.
Please be advised that this notice does not prevent the Division of Water Quality from taking
enforcement actions for this violation or any past or future violation. Furthermore, the Division
of Water Quality has the authority to levy a civil penalty of not more than $10,000.00 per day per
violation.
Please provide a written response to this office on or before February 15, 1998, regarding
corrective actions taken or planned. If you have any questions concerning this matter, please do
not hesitate to contact either myself or Mr. Robert Heath, Environmental Specialist, at (910) 485-
1541.
Sincerely,
Kerr T. Stevens
Regional Supervisor
cc: Sue Homewood - Compliance Group
Sam Warren - Bladen Co. NRCS
Audrey Oxendine - DSWC Fayetteville Office
Central Files - Raleigh

-
xvz�W,d,�'sr.?•.........,<. 9... ...K"E"-«-.e-...:c»a_.""'".+w^=:E""'.... .�°H�•`
xy 0 Division of Soil and Water Conservation 0 Other Agency"�
® Division of Water Quality
0 Routine 0 Complaint *Follow-up of DWQ inspection 0 Follow-up of DSWC review 0 Other
Date of inspection f .2.?
Facility Number r ©9 /G
—' Time of Inspection : 24 hr. (hh:mm)
© Registered M Certified © Applied for Permit ❑ Permitted [] not O eraGnnal Date
Last Operated:
FarmName: ........SQiJ.......... tf............................................................. County:..........:..IF..----......................................
Owner Name: ! ......... .. hone No: .................. ---. .....
....................................................................... ro...... ,2
Facility Contact:...............,,¢ ................. Title: ` . Phone No: .....................
Mailing Address:...................r..s....�...�s..Z dG.�....!/..�..rS.,<<✓f!j, ...N �....¢3..,�..............7 .
Onsite Representative:........... Integrator:.....- 1...-,✓!4
�.
Certified Operator: ... .............. _............................... ...... ................... .......... Operator Certification Number;
Location of Farm:
Latitude Longitude �• �� ���
,.y•Des Current
`Y.m�fi+ 'k� ..,ewwi.,' x�.;e. axrF� x �-+, gA rsrz'x5`A .��� a
o , vas .r,«x xk�r ^ �' .n6 -r3 st' `� "`DeSI Ka, r Cnrrent' '.,mow
drums : x � , � " `e'..ir.- � x`4 'xi vs.Q ntCrent�. =;
S�vime� Capacity Population Poultry Capacity Papuiahvti cattleaCapaeity �Popnlattin�.
rFeeder
Feeder
3
Finish / O l7 �,�Q f/O :"
o Wean..a�.:ksas�4o Feeder,,ate"'^o Finish "Y T6WDesign CSCCty �gg
•' :rat'+, .rPcN`
Total SSLW
r` ❑ Boars 3 r » ""a x «u sue.
.. .-. .... .. ... ... .. r4a` xi ro+ccvt,. r. 9.a,.✓arx'#, n,pd.:.kwei�%adk,l�y'
dumber oil
.,Lagoons / Holding Ponds ❑ Subsurface Drains Present ❑ Lagoon Area Spray Field Area
'#F`a�`{g`'r ,3', tzz�.. ye.o":t`as..., ... .... ..... ... .. ........ ... .. gr�au x,:...
�t
p "a;. rscs',�vf t ✓.,%7at'» AriSew.maoF>",�,4"
.t Y ems. •- ..� ❑ No Liquid Waste Management System.u,.
Non -Layer
� ❑Non -Dairy
❑Layer
,I[]
Dairy
General
1. Are there any buffers that need maintenance/improvement?
2. Is any discharge observed from any part of the operation?
Discharge originated at: ❑ Lagoon ❑ Spray Field ❑ Other
a. If discharge is observed, was the conveyance man-made?
b. If discharge is observed, did it reach Surface Water? (If yes. notify DWQ)
c. If discharge is observed, what is the estimated flow in gal/min?
A. Does discharge bypass a lagoon system'? (If yes. notify DWQ)
3. Is there evidence of past discharge from any part of the operation?
4. Were there any adverse impacts to the waters of the State other than from a discharge?
5. Does any part of the waste management system (other than lagoons/holding ponds) require
mai ntenancelimprovement?
6. Is facility not in compliance with any applicable setback criteria in effect at the time of design?
7. Did the facility fail to have a certified operator in responsible charge?
7/25/97
❑ Yes M No
❑ Yes IN No
❑ Yes
P9 No
❑ Yes
qNo
^//.0
❑ Yes
(N No
❑ Yes
� No
❑ Yes
� No
❑ Yes
�{No
❑ Yes
VfNo
❑ Yes
WNo
Continued or: back

Facility Number: d5 9 —
'8. Are there lagoons or storage ponds on site which need to be properly closed?
ElYes
; No
Structures (LaQoons.Holding Ponds, Flush Pits, etc.)
9. Is storage capacity (freeboard plus storm storage) less than adequate?
Yes
❑ No
Structure I Structure ? Structure 3 Structure 4 Structure 5
Structure 6
Identifier:
_.....---
Freeboardft ........... Q�...z ................................................. ...................... ...........
.......................
..............
10. is seepage observed from any of the structures?
❑ Yes
� No
11. Is erosion, or any other threats to the integrity of any of the structures observed?
❑Yes
�No
12. Do any of the structures need maintenancelimprovement?
Ayes
❑ No
(If any of questions 9-12 was answered yes, and the situation poses
an immediate public health or environmental threat, notify DWQ)
13. Do any of the structures lack adequate minimum or maximum liquid level markers?
❑ Yes
ANo
Waste Application
14. Is there physical evidence of over application?
❑ Yes
*No
(If in excess of WNW, or runoff entering waters of the State, notify DWQ)
15. Crop type d.4A-................_........... _..............................�..................................................._......................._........_......_.....................1........................
...................
16. Do the receiving crops differ with those designated in the Animal Waste Management Plan (AWMP)?
XYes
❑ No
17. Does the facility have a lack of ad�quate acreage for land application?
Ayes
❑ No
18. Does the receiving crop need improvement?
'Yes
❑ No
19. Is there a lack of available waste application equipment?
❑ Yes
JXNo
20. Does facility require a follow-up visit by same agency?
KYes
❑ No
21. Did Reviewer/Inspector fail to discuss review/inspection with on -site representative?
Yes
❑ No
22. Does record keeping need improvement?
❑ Yes
❑ No
For Certified or Permitted Facilities Only
23. Does the facility fail to have a copy of the Animal Waste Management Plan readily available?
❑ Yes
❑ No
24. Were any additional problems noted which cause noncompliance of the Certified AWMP?
❑ Yes
❑ No
25. Were any additional problems noted which cause noncompliance of the Permit?
❑ Yes
❑ No
No.violationssor' deficiencies. were noted -during this', visit'. You .'will receive. no,ftir er ' -
....................
:-;•ctirrespondenceab'outthis�yisit:-:�;-:�'� :�:•��:•�� �;�" ' "�:•�•:• •:•;�,� ��;-;-:-:•;-:-;�:�; :-:•,�-:•
$ ? aH - A` QK}}
Comments {refer, tohqueshon #) Ealsllala anyYES,ans�vers and/or any, recorntnenatons•or any outer comments:
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Use tit awt pigs pf4[acthty to better expiati sttuations ,(use addiriona! pages as>necessary):
AL
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7125197
Reviewer/Inspector Name x
Reviewer/Inspector Signature: Date: / 23

Division of Soil and Water Conservation ❑ Other Agency
Division of Water Quality
10 Routine O Complaint OfFollow-up of DWO inspection O Follow-up of DS'4'4'C review O Other
�� I L� Date of Inspection 7 /
Facilit} Number
Time of Inspection 24 hr. (hh:mm)
© Registered XCertified 0 Applied for Permit j�Permitted Not Operational Date Last Operated: ..,. -.....-
Farm Name:...... ease/.1.... m.$� ...................` ..........._. County:...FlqdeA...................................................
Owner Name:..... ........................... xea.....o'. ........ Phone No: ................................
Facility Contact:..... ......... 4 ��.�....... Title:.. ®Lc1AeIr Phone No:
.. . .....
-7
Mailing Address: C G Z..................................................... ..........................
... .......
OnsiteRepresentative: .. . ........ . ......................................... . ............... ............... .................. Integrator:... %Q .....................................................
Certified Operator,.....! 1!ry't £?.y.#1Q.. ..... Operator Certification Number ..- .................. !..._.. �..................... -....
Location of Farm:
Latitude 0' =' " Longitude =• =' ="
Des Current .,Desi'Gurrentl's aR Des'
f ;K� Currents TT
�' Swmc" Ca actt fP ulahon, , Po n. act 6 ulatron w Caitle
p Y op uY t3' p Ch Populafign
q
Boars
tauss
'To
#^.
vnw
Number ofsLagoons / Hoidutg Ponds ❑Subsurface Drains Present ❑Lagoon Area Spray Feld Area
''*4^�v}"'.wt
❑ No Liquid Waste Management System Ks
❑ Wean Feeder
era
Dairy
to
er
EEINon-Layerl
�a. � ❑Non -Dairy
��,•3� �"
❑ Feeder to Finish
❑ Farrow to Wean
.� Other
❑ Farrow to Feeder
�•� � a �� � : � ,� �-�,, � Total Design Capactty
Farrow to Finish
❑ Gilts
Y
General
1. Are there any buffers that need maintenance/improvement?
2. Is any discharge observed from any part of the operation?
Discharge originated at: ❑ Lagoon Spray Field ❑ Other
a. If discharge is observed, was the conveyance man-made?
b, if discharge is observed, did it reach Surface Water? (if yes, notify DWQ)
c. If discharge is observed, what is the estimated flow in gai/min?
A. Does discharge bypass a lagoon system? Of yes, notify DWQ)
3. Is there evidence of past discharge from any part of the operation?
4. Were there any adverse impacts to the waters of the State other than from a discharge?
5. Does any part of the waste management system (other than lagoons/holding ponds) require /'4
maintenance/improvement?
6. is facility not in compliance with any applicable setback criteria in effect at the time of design?
7. Did the facility fail to have a certified operator in responsible charge?
7/25/97
❑ Yes Lij.No
Yes ❑ No
❑ Yes go KNo
Yes ❑ No
ZD ns: n .
❑ Yes No
Yes ❑ No
❑ Yes J�LNo
Yes ❑ No
❑ Yes
9 No
Yes
❑ No
Continued on back

i
,y
Facility Number:
8. Are tkere lagoons or storage ponds on site which need to be properly closed?
Structures (Lagoons.Holding Ponds, Flush Pits, etc.)
9. Is storage capacity (freeboard plus storm storage) less than adequate?
Structure I Structure 2 Structure 3 Structure 4
❑ Yes Z(fNo
❑ YesXNo
Structure 5 Structure 6
Identifier:
41........ n............................................................................. .......... ..................... .........
Freeboard (ft): ..........�.
............................................................................................................................................................................................
10. Is .seepage observed from any of the structures? ❑ Yes J4No
I I- Is erosion, or any other threats to the integrity of any of the structures observed? XYes ❑ No
12. Do any of the structures need maintenancelimprovement? XYes ❑ No
(if any of questions 9-12 was answered yes, and the situation poses
an immediate public health or environmental threat, notify DWQ)
13. Do any of the structures lack adequate minimum or maximum liquid level markers?
Waste Application
14. is there physical evidence of over application?
(If in excess of WMP, or runoff entering waters of the State, notify DWQ)
15. Crop type ....P M.�_:
16. Do the receiving crops differ with those designated in the Animal Waste Management Plan (AWMP)?
17. Does the facility have a lack of adequate acreage for land application?
18. Does the receiving crop need improvement?,
19. is there a lack of available waste application equipment?
20. Does facility require a follow-up visit by same agency?
21. Did Reviewerfinspector fail to discuss review/inspection with on -site representative?
22. Does record keeping need improvement?
For Certified or Permitted Facilities Only r
23. Does the facility fail to have a copy of the Animal Waste Management Plan readily available?
24. Were any additional problems noted which cause noncompliance of the Certified AWMP?
25. Were any additional problems noted which cause noncompliance of the Permit?
❑ Yes KNo
Ayes ❑ No
0. No.violitions or deft.eiencies4ere'noted dtiring this" visit. - You'wili i&ei ive-iro•ftirihei'-:
-:-i•tirresppndence.ab�out�fhis'visit:.....:.....:..:. .........
Ayes ❑ No
yes ❑ No
Yes ❑ No
14
❑ Yes 0io
XYes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
��` ��� � �r .� �- � YES: answers flntilor�an r�om�endattotis or ari other ficoinrnents �� ,Comments (refer�to�questron #t).�Explatm any, �. Y� _'� y
USe dr8wings pf,fflethty toabettes explain situataORS (use fldditi4nal Vpages as:necessflry) .ems' �� a u�-.�;
sai•.i?'�a. �5 nee» ., .1"� .. ;,o s4.S .�,�,3..,w ,, .iy,�.`." �., �:,.-�v.� . .
7/25197
Relv7ewer/Inspector Name EA r .. ,
Reviewer/ImpectorSignature: L Date: 1

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State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
October 6, 1997
CERTIFIED MAIL.
RETURN RECEIPT REQUESTED
ATTN: Ray Reason
P.O. Box 637
Elizabethtown, NC 28337
RECEIVED"
OCT 10 1997
FAYEfTEVILLE
REG. OFFICE
Subject: Notice of Violation and
Assessment of Civil Penalty for
Violation of G.S. 143-215. 1 (a)(2).
Reason One Farm
Facility #: 09-016
Bladen County
Case #: AL 97-016
Dear Mr. Reason:
This letter transmits a Notice of Violation and notice of a civil penalty assessed against
Ray Reason in the amount of $500.00. This assessment is based upon the following facts:
A permit for this animal waste management system is required in accordance with NCAC
2H .0217 and G.S. 143-215.1.
In accordance with G.S. 143-215. IOC, Ray Reason was notified by certified mail, which
was received on July 17, 1997, of the requirement to apply for coverage under an Animal
Waste General Permit within thirty (30) days of receipt of the notification (August 16,
1997).
No application from Ray Reason has been received as of September 17, 1997.
In accordance with Chapter 626 of the 1995 Session Laws (Regular Session 1996),
Section 19(c)(2), any owner or operator who fails to submit an application by the date
specified by the Department SHALL NOT OPERATE the animal waste system after the
specified date. Therefore, the existing animal waste management system is being operated
in violation of G. S. 143-215. 1 (a)(2).
Based upon the above facts, i conclude as a matter of law that Ray Reason violated or
failed to act in accordance with the requirements of G.S. 143-215. 1 (a)(2). A-civilpenalty
of not more than $10,000 per day may be assessed against a person who is required but
fails to apply for or to secure a permit required by G.S. 143-215.1.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

Based upon the above facts and conclusions of law, I hereby assess Ray Reason a $500.00
civil penalty for this violation of G.S. 143-215. 1 (a)(2) pursuant to the authority delegated
to me by North Carolina Environmental Management Commission Regulation 15 NCAC
2J .0003 and G.S. 143-215.6A(h)_ y
If the aforementioned application is not received by the Division of Water Quality
Compliance Group office at the letterhead address within 10 days of your receipt of this
notice, you will be subject to further civil penalties of up to $10,000 for each day that the
application is late.
Within thirty days receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should -be made directly to the Department of Environment, Health, and
Natural Resources (do.not include. waiver. form). Payment of the penalty will not
foreclose enforcement action for any continuing or new violation(s). Please submit
payment to the attention of:
Mr_ Steve W. Tedder
Water Quality Section Chief
Division of Water Quality
P.O. Box 29535
Raleigh, North Carolina 27626-0535
or
2. Submit a written request for remission or mitigation including a detailed
justification for such request:
A request for remission or mitigation is limited to consideration of the
reasonableness of the amount of the penalty and is not the proper procedure for
contesting the accuracy of any of the statements contained in the assessment letter.
Because a remission request forecloses the option of an administrative hearing, such
a request must be accompanied by a waiver of your right to an administrative
hearing and a stipulation that there are no factual or legal issues in dispute. You
must execute and return to this office the attached waiver and stipulation form and a
detailed statement which you believe establishes whether:
(a) one or more of the civil penalty assessment factors in G.S. 143B-282.1(b)
were wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting
from the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining
necessary remedial actions.
Please submit this information to the attention of:

Mr. Steve W. Tedder
Water Quality Section ChieflDWQ
P.O. Box 29535
Raleigh, North Carolina 27626-0535
OR
3. Submit a written request for an administrative hearing:
If you wish to. contest any portion of the civil penalty assessment, you must request
an administrative hearing. This request must be in the form of a written petition to
the Office of Administrative Hearings and must conform to Chapter 150B of the
North Carolina General Statutes. You must:
File your original petition with the:
Office of Administrative Hearings
P.O. Drawer 27447
Raleigh, North Carolina 27611-7447
and
Mail or hand -deliver a Copy of the petition to:
Mr. Richard Whisnant
Office of General Counsel
NCDEHNR
Post Office Box 27687
Raleigh, NC 27611
Failure to exercise one of the options above within th_Y days, as evidenced by a date
stamp (not a postmark) indicating when we received your response, will result in this matter being
referred to the Attorney General's Office with a request to initiate a civil action to collect the
penalty. Please be advised that additional assessments may be levied for future violations which
occur after the review period of this assessment.
If you have any questions, please contact Mr. Shannon Langley at [phone],
extension 581 or Katharine Keaton at [phone], extension 532.
Sincerely, I
r
A Preston Howard, Jr., P. .
ATTACHMENTS
cc: FiyetteviRF-Re'gional--Supervisor�-w/_attachments
Compliance/Enforcement File w/ attachments
Central Files w/ attachments
Public Information Officer w/attachments

STATE OF NORTH CAROLINA
COUNTY OF
ENVIRONMENTAL MANAGEMENT
CO1\QyRSSION
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
PERMIT NO. ) STIPULATION OF FACTS
FILE NO.
Having been assessed civil penalties totalling for
violation(s) as set forth in the assessment document of the Director of the Division of Water Quality
dated, , the undersigned, desiring to seek remission of the civil
penalties, does hereby waive the right to an administrative hearing in the above -stated matter and does
stipulate that the facts are as alleged in the assessment document.
This the
day of
0090"TaRR
TELEPHONE
SIGNATURE
19-

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Water Quality
Non -Discharge Permit Application Form / Survey
(THIS FORM MAY BE PHOTOCOPIED FOR USE AS AN ORIGINAL)
General Permit - Liquid Animal Waste Operations
The following questions have been completed utilizing . information on file with the
Division. Please review the information for completeness and make any corrections
which are appropriate. If a question has not been completed by the Division, please
complete as best as possible. Do not leave any question unanswered.
Application Date:
I. REQUIRED ITEMS CHECKLIST
Please indicate that you have included the following required items by signing your initials in the space provided next to each
item.
Applicants Initials
1. One completed and signed original and one copy of the application for General Permit -Animal
Waste Operations;
2. Two copies of a general location map indicating the location of the animal waste facilities and
field locations where animal waste is disposed;
3. Two copies of the Certified Animal Waste Management Plan (CAWMP). If the facility does
not have a CAWMP, one must be completed prior to submittal of a general permit application
for animal waste operations.
II. GENERAL INFORMATION:
1. Farm's name: -Reason One
2. Print Land Owner's name: Ray- Reason
3. Land Owner's Mailing address: _ PO Box 637
City: Elizabethtown NC _ _ Zip: 28337
Telephone Number: 862-4107 _
4. County where farm is located: J3ladrn
5. Farm Location (Directions from nearest major highway. Please include SR numbers for state roads. Please include a copy
of a county road map with the location of the farm identified): From Elizabethtown take Mercer Road approx. 4 miles to
R9sendaIe Rgad. tumeft go to Lisbon_ Road intersection. go straight on Rosendale Road approx. 1 mile -to farm on -fight.
6. Print Farm Manager's name (if different from Land Owner):
7. Lessee's I Integrator's name (if applicable; please circle which type is listed): Brown's of CarollnaBrown of Carolina. Inc.
�y •
FORM: AWO-G-E 2/26/97 Page 1 of 3

III. OPERATION INFORMATION:
1. Farm No.: 09-16
2. Operation Description: Swine o ration
Feeder to Finish
6400 - Certified Design Capacity
Is the above information correct? 0 yes; Elno. If no, correct below using the design capacity of the facility
Type of Swine No. of Animals Type of out No. of Animals Tyne of Cattle No. of Animals
0 Wean to Feeder 0 Layer 0 Dairy
0 Feeder to Finish 0 Non -Layer 0 Beef
0 Farrow to Wean (# sow) 0 Turkey
0 Farrow to Feeder (# sow)
0 Farrow to Finish (# sow)
Other Type of Livestock on the farm: No. of Animals: _
3. Acreage cleared and available for application: 55.00 ; Required Acreage (as listed in the CAWMP):
4. Number of Lagoons: 1 ; Total Capacity: Cubic Feet (ft3)
Number of Storage Ponds: ; Total Capacity: Cubic Feet (ft3)
5. Is animal waste being applied on any field which has subsurface drains? YES or NO
6. Are subsurface drains present in the vicinity of or under the lagoon? YES or NO
I V . APPLICANT'S CERTIFICATION:
1,
(please circle one)
(please circle one)
(Land Owner's name listed in question 1I.2), attest that
this application for (Farm name listed in question H.1)
has been reviewed by me and is accurate and complete to the best of my knowledge. I understand that if all required parts of this
application are not completed and that if all required supporting information and attachments are not included, this application package
will be returned to me as incomplete.
Signature
Date
V . MANAGER'S CERTIFICATION: (complete only if different from the Land Owner)
(Manager's name listed in question 1I.6), attest that this
application for (Farm name listed in question II.1)
has been reviewed by me and is accurate and complete to the best of my knowledge. I understand that if all required parts of this
application are not completed and that if all required supporting information and attachments are not. included. this application package
will be returned as incomplete.
Signature
Date
THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING INFORMATION AND MATERIALS,
SHOULD BE SENT TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DIVISION OF WATER QUALITY
WATER QUALITY SECTION
PERMITS AND ENGINEERING UNIT
POST OFFICE BOX 29535
RALEIGH, NORTH CAROLINA 27626-0535
TELEPHONE NUMBER: [phone]
FORM: AWO-G-E 2/26/97 Page 2 of 3

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Water Quality
Non -Discharge Permit Application Form / Survey
(THIS FORM MAY BE PHOTOCOPIED FOR USE AS AN ORIGINAL)
General Permit - Liquid Animal Waste Operations
DIVISION OF WATER QUALITY REGIONAL OFFICES (2/97)
Asheville Regional WQ Supervisor
59 Woodfin Place
Asheville, NC 28801.
[phone]
Fax [phone]
Avery
Macon
Buncombe
Madison
Burke
McDowell
Caldwell
Mitchell
Cherokee
Polk
Clay
Rutherford
Graham
Swain
Haywood
Transylvania
Henderson
Yancey
Jackson
Fayetteville Regional WQ Supervisor
Wachovia Building, Suite 714
Fayetteville, NC 28301
[phone]
Fax [phone]
Washington Regional WQ Supervisor
943 Washington Square Mall
Washington, NC 27889
[phone]
Fax [phone] -
Beaufort Jones
Bertie
Lenoir
Camden
Martin
Chowan
Pamlico
Craven
Pasquotank
Currituck
Perquimans
Dare
Pitt
Gates
Tyrell
Greene
Washington
Hertford
Wayne
Hyde
Mooresville Regional WQ Supervisor
919 North Main Street
Mooresville, NC 28115
[phone]
Fax [phone]
Anson
Moore
Alexander
Lincoln
Bladen
Richmond
Cabarrus
Mecklenburg
Cumberland
Robeson
Catawba
Rowan
Harnett
Sampson
Cleveland
Stanly
Hoke
Scotland
Gaston
Union
Montgomery
Iredell
Winston-Salem Regional WQ Supervisor
585 Waughtown Street
Winston-Salem, NC 27107
[phone]
Fax [phone]
Alamance
Rockingham
Alleghany
Randolph
Ashe
Stokes
Caswell
Surry
Davidson
Watauga
Davie
Wilkes
Forsyth
Yadkin
Guilford
Raleigh Regional WQ Supervisor
3800 Barrett Dr.
Raleigh, NC 27609
[phone]
Fax [phone]
Chatham
Nash
Durham
Northampton
Edgscombe
Orange
Franklin
Person
Granville
Vance
Halifax
Wake
Johnston
Warren
Lee
Wilson
Wilmington Regional WQ Supervisor
127 Cardinal Drive Extension
Wilmington. NC 28405-3845
[phone]
Fax [phone]
Brunswick New Hanover
Carteret Onslow
Columbus Pender
Dupiin
FORTH: AWO-G-E 2/97
Page 3 of 3

.State of North Carolina
Department of Environment,
Health and Natural Resources Aviol
Fayetteville Regional Office
James B. Hunt, Jr., Governor p E H N
Jonathan B. Howes, Secretary
DIVISION OF WATER QUALITY
June 17, 1997
u�
it 11K# es m a r i ; 1 JI I«
Mr. Ray Reason
P. O. Box 2201
Elizabethtown, N. C. 28337
SUBJECT: NOTICE OF DEFICIENCY
Reason One Swine Farm
Facility No. 09-16
Bladen County
Dear Mr. Reason:
On June 12, 1997, staff from the Fayetteville Regional Office of the Division of Water Quality
conducted an inspection at Reason One Swine Farm to determine compliance with their certified
animal waste management plan (CAWMP). At the time of the investigation our staff confirmed that
the facility had not planted a crop (bermuda grass). In addition, the lagoon had no grass cover to
prevent erosion and no waste analysis had been collected or analyzed. The 55 acres of waste
application spray field were cleared, however; large piles of trees were still remaining in the spray
field area and had not been prepared for planting. The waste application records were not completed
because the waste analysis was not available. The Division of Water Quality may proceed with
additional actions against Reason One Swine Farm, unless the following items are addressed:
I _ Immediately plant the required crop (coastal bermuda) per your Certified Animal Waste
Management Plan (CAWMP) in the 55 acre spray application field to allow for the application of
waste at agronomic rates.
2. Immediately collect a waste analysis sample to comply with the CAWMP and so adequate
records may be maintained of the waste application on the crop.
3. Consult with a technical specialist with the Agriculture Extension Office knowledgeable in
grass cover for erosion control.
Wachovia Building, Suite 714, Fayetteville ��y. FAX [phone]
North Carolina 28301-5043 N�� C An Equal Opportunity Affirmative Action Employer
Voice 910-486-1541 50% recycled/10% post -consumer paper

Page 2
Mr. Ray Reason
June 17, 1997
Nothing in this letter should be taken as absoh* this facility of the responsibility and liability
of any violations that have or may result from these deficiencies.
Please provide a written response to this office on or before July 6, 1997, regarding
corrective actions taken or planned. If you have any questions concerning this matter, please do not
hesitate to contact me at [phone].
Sincerely,
Robert Heath
Environmental Specialist
KTS/RFH
cc: Operations Branch
Central Files
Audrey Oxendine, FRO, NC DSWC
Sam Warren, Bladen County MRCS

V'CI.NITY MAP
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