310294_Lagoon Sampling_20180521

F C1.
Water Resources
En,uontncntul Qualu4
May 21, 2018
CERTIFIED MAIL 7016 2140 0000 0562 4332
RETURNRECEIPT REQUESTED
Jason Phillips
H&J Nursery # 1 - 3
279 Johnson Church Rd
Warsaw, NC 28398
SUBJECT: Lagoon Sampling - April 13, 2018
H&J Nursery # 1 - 3
Permit # AWS310294
Duplin County
Dear Jason Phillips:
ROY COOPER
MICHAEL S. REGAN
Senrraq
LINDA CULPEPPER
lntmm L>irecior
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/agronomi/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.
The results show a significant difference in the PAN concentrations as well as other macro and micro
nutrients for lagoon HN 1 And HN2 that put into questions the validity of the March 171 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. 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 17th sampling results for lagoon HNl and HN2 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 17'h sampling data is included below.
',-Nwhing Comparrs =-_,
State of North Carolina I Environmental Quality I Division of Water Resources
Water Qasaty Regional operations Section
1636 Mail Service Center I Raleigh, North Carolina 27699-1636
919-707-9129

Lagoon Sampling - April 13, 2018
Page 2
Lagoon Name: 1011
Sample Results img'1, PAN in lbsJ1000gallons)
j 3/17 - 4/13
Parameter 3/17/2018 4/13/2018 Difference % change
TKN 518
PAN 2.2
2026
1508
291%
8.4
6.3
291%
39
496
458
1182%
423
947
524
124%
Ca 107 -r
622
515
481%
Mg 26
200
174
668% j
28
479
451
1586%
Fe 2.0
Mn M 0.3
0.5
Cu 0.2
0.4
Na 164.3
327.2
325.2
14.8
515.7
15955%
5574%
1 101108%
15.0 -
516.2
58.9
58.7
1.0
34955%
235%
1.5
663.7
7.4
499.4
304%
7.5
-0.1
-1%
0.5
0.3
-0.2
j -40%
Lagoon Name: 13N2
Sample Results m PAN in IbsJ1000gallons)
3/17 - 4/13
Parameter 3/17/2018 4/13/2018 Difference % change
539
2.2
1469
6.1
930
3.9
173%
173%
40
307
267
660%
418
806
388
93%
109
449
340
312%
27
108
81
300%
29
331
302
1030%
2.3
223.7
221A
9543%
0.3
10.9
10.6
3645%
0.7
365.8
365.1
50773%
0.2
41.5
41.3
18281%
0.5
1.0
0.6
118%
163.0
470.8
307.8
189%
7.4
7.6
0.2
30%
0.9
0.2
-0.7
-73%

Lagoon Sampling — April 13, 2018
Page 3
Lagoon Name: HN3
Sample Results (mg/1, PAN in lbs./1000 gallons)
3/17 - 4/13
Parameter 3/17/2018 4/13/2018 Difference % change
TKN 556
PAN 2.3
683
2.8
127
0.5
23%
23%
' 40
39
-2
-4%
434
725
291
67%
Ca Ill
109
-2
-2%
27
13
-13
-50%
30
19
-11
-37%
Fe 2.3
4.2
1.9
81%
Iln 0.3
0.3
0.0
-2%
Zn 0.6
2.6
2.0
318%
Cu 0.2
0.5
0.3
162%
0.4
0.8
0.4
83%
Na 168.2
101.3
-66.9
-40%
7.5
7.9
0.4
5%
0.6
Three lagoons were sampled at your farm. Concentrations reported for the three lagoons in March 2018
were noticeably more similar to one another than compared to the April sampling results. The variation
found in the April 13 sampling analysis is much more consistent with normal variations found in swine
lagoon effluent is NC. The following two tables show the differences reported for your lagoons for the
March and April Sampling Events.

Lagoon Sampling - April 13, 2018
Page 4
3/17/2018 Sampling Results -�
m 1 PAN in lbs./1000gallons)
La oon ID
Parameter IIN1 HN2 HN3 Ranee
518
539
556
38
2.2
2.2
2.3
0.2
39
40
40
2
423
418
434
16
107
109
ill
4
26
27
27
1
28
29
30
1
2.0
2.3
2.3
0.3
0.3
0.3
0.3
0.0
0.5
0.7
0.6
0.2
0.2
0.2
0.2
0.1
t 0.4
0.5
0.4
0.0
164.3
163.0
168.2
5.2
7.5
7.4
7.5
0.1
0.5
0.9
0.6
0.5
4/13/2018 Sampling Results
m 1l PAN in lbsJ1000gallons)
Lagoon ID
Parameter HN1 HN2 HN3 Ran e
2026
1469
683
1344
8.4
6.1
2.8
5.6
496
307
39
458
947
806
725
222
622
449
109
514
200
108
13
1 187
479
331
19
460
327.2
223.7
4.2
323.0
15.0
10.9
0.3
14.8
516.2
365.8
2.6
513.5
58.9
41.5
0.5
58.4
1.5
1.0
0.8
0.7
663.7
470.8
101.3
562.4
7.4
7.6
7.9
0.5
0.3
0.2
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 investieation Please Provide the followine 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,
Jon Risgaa/6k
Chief, Water Quality Regional Operations Section
Division of Water Resources
Enclosure
cc: Wihmington WQROS Regional Supervisor
WQROS Central Files