310049_Certified Mail - Lagoon Sampling_20180604

Water Resources
i'n:ironmem::! �n,n13a
June 4, 2018
CERTIFIED MAIL 7016 2140 0000 0562 4189
RETURNRECEIPT REOUESTED
Edward Dail
Dail Brothers & Edward Dail 5-12
825 NC 24 East
Kenansville, NC 28349
SUBJECT: Lagoon Sampling - April 13, 2018
Dail Brothers & Edward Dail 5-12
Permit # AWS310049
Duplin County
Dear Edward Dail:
ROY COOPER
Gcviav;m
MICHAEL S. REGAN
Secrerary
LINDA CULPEPPER
lnterim Drrerlor
Thank you for your cooperation in the Division's lagoon waste sampling efforts on April 13, 2018. On that
day seven teams of Division staff sampled 35 farms and a total of 55 waste lagoons. Multiple teams were
necessary to assure that teams followed proper biosecurity protocols to protect your animals. I apologize
for the short notice that was provided to you by our staff. It was our intent to do the sampling as efficiently
and effectively as possible with as little disruption to you and other operators. Staff notified you as soon
as possible once we were comfortable that weather would cooperate and we had staff prepared to complete
the desired sampling on a single day. Complete results of the sampling are available on the NCDA&CS
Agronomic Services Division PALS website and can be accessed there at your convenience.
http://www.ncagr.gov/agronon3i/pals/
The Division submitted the samples to the lab on April 13, and the standard waste analysis was performed
the following week. The certified results are available to use for loading rate calculations in you waste
application records. Our staff followed sampling protocol established by NCDA&CS Agronomic Sampling
Folder No. 6, revised April 2014, a copy of which is included with this letter. You may at any time resample
your lagoons to establish updated results if you feel more representative sample is desired for future
application events.
One of the intents of the sampling effort was to look at observed changes in lagoon sampling results in a
relatively short period of time. Our records show that a previous sampling event took place on March 17,
2018. Results of the April 13 and March 17 sampling events are shown on the following pages for each
lagoon sampled on your farm.
No€hifctl Cv(ripares`
State of North Carolina I Environmental Quality I Division of Water Resources
Water Quality Regional operations Section
1636 Mail Service Center I Raleigh, North Carolina 27699-1636
919-707-9129

Lagoon Sampling - April 13, 2018
Page 2
Four lagoons were sampled at your farm. The following two tables show the differences reported for your
lagoons for the March and April Sampling Events.
3/1712018 Sampling Results
(mg/l, PAN in lbs.11000 gallons)
La loon ID
Parameter PC Sow T 5-12
170 549 5- 516
2.3 2.3 2.2
40 39 41
443 436 442
111 110 ill
Garner
545 y
2.3
i 40
451
113
27
27
28
27
30
29
30
30
2.3
2.1
2.2
2.3
0.3
0.3
0.3
0.3
0.6
0.5
0.6
0.6
0.2
0.2
0.2
t 0.2
0.5
0.5
0.5
0.5
171.8
170.8
170.1
174.3
7.5
7.5
7.5
7.5
0.5__
0.5
0.5
0.1 _Ji
4/13/2018 Sampling Results
m 1 PAN in IbsJ1000gallons)
La oon ID
Parameter Finish L. Sow M Sow U. Sow
TKN 1630
1324
548
546
PAN 6.8
5.5
2.3
2.3
' 517
372
4.4
41
770
720
497
501
Ca 569
551
ill
100
352
191
28
26
219
121
29
33
Fe 135.4
78.8
2.8
1.9
Mn 1 1.2
6.8
0.4
0.3
Zn 48.6
33.3
0.7
0.5
49.2
6.2
0.2
0.3
0.9
0.9
0.4
0.4
Na 222.0
191.3
146.7
154.6
7.6
Al 0.2
7.5
7.7
7.7
0.2
0 1
-
While it is unclear which of the lagoon samples collected by the Division correspond to the lagoon samples
collected in March, the results show a significant difference in the PAN concentrations as well as other
macro and micro nutrients that put into questions the validity of the March 170' sampling results. It is
unlikely that a lagoon make-up will change significantly in a month without significant operations event
occurring like a lagoon sludge clean out. Concentrations reported for two lagoons (Finish and L. Sow) in
April 2018 were significantly different than the other samples tested in March and April sampling.
As a result of initial evaluation of the sampling results the Division will be conducting additional evaluation
of historic data at your farms and at the other farms that were sampled on April 13, 2018. It is necessary to
further investigate the unusual changes in lagoon characteristics between March 17 and April 13, 2018.
To assist in the invcsti;tation please provide the followine to the Wilmineton Regional Office no later than
July 3, 2018.
• Results of the last two years of sludge survey, including information on who conducted the survey.
• Records of any sludge removal that occurred between March 17 and April 14, 2018.
• Any operational changes that may have contributed to the lagoon characteristics between March
17 and April 13, 2017.
• Results of any additional lagoon waste analysis for the lagoon in question conducted since March
17,2018

Lagoon Sampling — April 13, 2018
Page 3
Please contact the Wilmington Regional Office at [phone] or Christine Lawson at (919) 807- 6354
if you have further questions.
Sincerely,
Jon Risgaard
Chief, Water Quality Regional Operations Section
Division of Water Resources
Enclosure
cc: Wilmington WQROS Regional Supervisor
WQROS Central Files