310232_Lagoon Sampling_20180521

t.
Water Resources
Environmental Quality
May 21, 2018
CERTIFIED MAIL 7016 2140 0000 0562 4257
RETURNRECEIPT REQUESTED
Milton Hunter
Hunter Farms
805 Cypress Creek Rd
Wallace, NC 28466
SUBJECT: Lagoon Sampling -April 13, 2018
Hunter Farms-
Permit #—AWS310232p 1
Duplin County
Dear Milton Hunter.
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interne amclar
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 biosecln-ity 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.neagr.govlagronomi/paW
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
FolderNo. 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.
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 17th sampling results. It is unlikely that a l jigoon
make-up will change significantly in a month without significant operations event occurring like a lagoon
sludge clean out. Staff also noted a high observed sludge blanket in your lagoon; however, have not yet
obtained records of the last sludge survey to verify visual observation. For these reasons the Division has
deemed the March 171 sampling results for lagoon HF1 to be invalid until additional information or
explanation can be provided to justify differences in sampling results. More details on the information
requested to validate the March 171 sampling data is included below.
­�Y Nothing Compares=ate.
State of North Caro11na I Environmental Quality I Division of WaterResuaces
Water Quality Regional operations Section
1636 Mali Service Center I Raldgh, North Camllna27699-1636
919-707-9129

Lagoon Sampling - April 13, 2018
Page 2
Lagoon Name: HFl
Parameter
Sample Results (mg/I, PAN in Ibs.11000gallons)
3/17/2018
4/13/2018
3/17-4/13
Difference
% change
553
2674
2121
384%
2.3
11.1
8.8
384%
41
1851
1810
4461%
441
1019
579
131%
112
27
1060
948
946%
1227
1200
4427%
30
395
365
1230%
2.4
2305
228.1
9678%
0.3
62.9
62.6
21380%
0.6
136.6
135.9
21543%
0.2
107.8
107.6
48693%
0.5
1.9
1.4
296%
170.7
3792
208.5
122%
7.5
7.3
-0.2
3%
0.6
0.5
-0.1
19%
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 investigation please nrovide the following to the Wilmington Regional Office no later than
June 21, 2018.
• Results of the last 2 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
Please contact the Wilmington Regional Office at [phone] or Christine Lawson at (919) 807- 6354
if you have further questions.
Sincerely, �
i
on Risg d
Chief, Water Quality Regional Operations Section
Division of Water Resources
Enclosure
cc: Wilmington WQROS Regional Supervisor
WQROS Central Files