330013_PERMIT FILE_20171231

STATE OF NORTH CAROLINA
Department of Environment and Natural Resources
Raleigh Regional Office
3800 Barrett Drive, Suite 101, Raleigh, NC 27609
919/571-4700
File Access Record
SECTION
TIMEIDATE
NAME
REPRESENTING:
Guidelines for Access: The staff of the°:Raleigh Regionai Office is dedicated to making public records in.our
custody readily available to the public for review and copying. We also have the responsibility to the public to
safeguard these records and to carry out our day-to-day program obligations. Please read carefully the following
euldelines before slanina the form
We prefer that you call at least a day in advance to schedule an appointment to review the files.
Appointments will be scheduled between 9:00 a.m. and 3:00 a.m. Viewing time ends at 5:00
p.m. Anyone arriving without an appointment may view the files to the extent that time and
staff supervision is available.
2. You must specify files you want to review by facility name. The number of fifes that you may
review at one time will be limited to five.
3. You may make copies of a file when the copier is not in use by the staff and if time permits. Cost
per copy is 10 cents for ALL copies if you make more than 25 copies - there is no charge for
less than 25 copies; payment may be made by check, money order, or cash at the reception
desk. You can also be invoiced.
4. FILES MUST BE KEPT IN THE ORDER YOU FOUND THEM. Files may not be taken from the
office. To remove, alter, deface, mutilate, or destroy material in one of these files is a misdemeanor
for which you can be fined up to $500.00.
5. In accordance with General Statute 25-3-512, a $20.00 processing fee will be charged and
collected for checks on which payment has been refused.
1.
2.
3.
4.
5.
FACILITY NAME
k �,
COUNTY
EF
Signs ure and Wime of Firm/Business Date Time In Time Out
Please attach a bushxaa cmd to this fam

State of North Carolina
Department of Environment,
Health and Natural Resources
Raleigh Regional Office
James B, Hunt, Jr., Governor
Jonathan B, Howes, Secretary
0EEHNFR
DIVISION OF WATER QUALITY
July 28, 1997
Mr. Doug Bunting
Route 1, Box 144-B
Pinetops, North Carolina 27864
Subject: Compliance Evaluation Inspection
Removal Request
Facility # 33-13
Cabell Farm
Edgecombe County
Dear Mr. Bunting:
On July 17, 1997, Mr. Buster Towell from the Raleigh Regional
Office conducted an annual inspection to determine compliance with
the State's animal waste nondischarge regulations.
The inspection determined that the facility was not operational and
that no discharges of wastewater were observed to any waters of the
State.
At your request, the Raleigh Regional Office will recommend that
your animal operation be removed from the registration data base.
Please note that if some time in the future you wish to reopen this
facility you will be required to have a General Permit prior to
restocking the facility and meet any current buffer\set back
requirements in place at the time of repopulation.
The Raleigh Regional Office appreciates your cooperation and
compliance. If you have any questions concerning this inspection
please call Mr. Buster Towell at [phone].
Sincerely �, ��/
� W+S'�
dy Irrett,
Water Quality Supervisor
cc: Edgecombe County Health Department
Mr. A.B. Whitley, Edgecombe Soil and Water
Conservation District
Ms. Margaret O'Keefe, DSWC-RRO
DWQ Compliance Group
RRO Files
3800 Barrett Drive, Suite 101, �!� FAX [phone]
Raleigh, North Carolina 27609 N%f C An Equal Opportunity Affirmative Action Employer
Voice 919-571-4700 50% recycled/ 10% post -consumer paper

�j Date of Inspection 7= 7_
Facility Number I
Time of Inspection `j 24 hr. (hh:mm)
Farm Status: ❑ Registered ❑ Applied for Permit
❑ Certified ❑ Permitted
❑ Not Operational Date Last Operated:
Total Time (in fraction of hours
(ex:1.25 for I hr 15 min)) Spent on Review /S
lor Inspection (includes travel and nrocessmol
Farm Name: .!..G..`1....r?.r..h^-.......
n !?✓ S(✓! r.l
_........_........ _.......
Land Owner Name: ,'Ds:4f. .. . ?. .1.. 1........................................
J
Facility Couctact:.�rr��Q��Lay�// . ? !e l._ �I....................... Title:....................,
Mailing Address:...j!�I .... `._.... !J_�..i�...�.��1....: �.._...... e
Onsite Representativep. 4-1 j ru.... z1. n...d1.bA............................................
Certified Operator:.... �..lD_� ....k.�f..^...T (^..............................................
Location of Farm:
Latitude
County:
Phone No:
�....._...........
..I —.....BZ?...-_y�...Y..._z.
Phone No: ............ . ........ ------- - -----------
......'Yc... _.....QQ.._..�.2z?.6.._.Y...._............. ....... _.................
Integrator: ... 1!!•l4.!t:.?....._........................................
Operator Certification Number: ..........................................
Longitude =• =, 0«
General 1Arthere any buffers that need maintenance/improvement? ❑ Yes �No
2. Is any discharge observed from any part of the operation? ❑ Yes {duo
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 gallmin?
d. 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
4/30/97 maintenance/improvement?
❑ Yes No
❑ Yes ;O`
❑ Yes No/
_❑ Yes ��rv0 Y
❑ Yes 0
❑ Yes';.I�'N0
Continued on back

Facility Number,,5.,..... -I-A ........,
6. Is Facility not in compliance with any applicable setback criteria in effect at the time of design?
❑ Yes
ZrNo
7. Did the facility fail to have a certified operator in responsible charge?
❑ Yes
No
be
8. Are there lagoons or storage ponds on site which need to properly closed?
❑ Yes
No
Structures (Lagoons,and/or TIQlding Ponds)
9, Is storage capacity (freeboard plus storm storage) less than adequate?
❑ Yes
Ld'No
Freeboard (ft): Structure I Structure 2 Structure 3 Structure 4 Structure 5
Structure
6
62 c..0......... ............................ ......................... ............................ ............................
................,.,.,.......�..
10. Is seepage observed from any of the structures?
❑ Yes
CTNo
11. Is erosion, or any other threats to the integrity of any of the structures observed?
Cl Yes
Er o�
12. Do any of the structures need maintenance/improvement?
❑ Yes
Q 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
ZNQ
Apste Application
14. Is there physical evidence of over application? p u S5 i 4 /.s,
❑ Yes
❑ No
(If in excess of WMP, or runoff entering waters of the State, notify DWQ)
15. Crop type ... 1...G�...Jrjdg ................................................................................................................................................
I6. Do the receiving crops differ with those designated in the Animal Waste Management Plan (AWMP)?
❑ Yes
❑ No
17. Does the facility have a lack of adequate acreage for land application?
❑ Yes
❑ No
18. Does the receiving crop need improvement?
es Now
19. Is there a lack of available waste application equipment?
❑ Yes
[❑
L0-l'N�/o
20. Does facility require a follow-up visit by same agency?
El Yes
ISO
21. Did Reviewer/Inspector fail to discuss review/inspection with on -site representative?
❑ Yes
ON-1
22. Does the facility fail to have a copy of the Animal Waste Management Plan readily available?
❑ Yes
❑ No
23. Were any additional problems noted which cause noncompliance of the Certified AWMP?
❑ Yes
❑ No
24. Does record keeping need improvement?
❑ Yes
❑ No
C
K ^,. -- ins "'k Q $is. onitnents,{refer to"question;#) Explairi°any YES answers and/or any recommendations or any; other comments .,,
Use drawings of facility to better explain situations `(use additional ages. as necessary)._
= A C. 1. I Y I -n S 'q_t14_ 1 4V Oc l /:fr�J&j , s-4,a.-/ - A, far�.s /feu. 4
�.1 y s S W-Xfs A94
►4m ft ra / ` � s tfl' W . JC S
i";'f1dR"!�""'S.^ '^a+ M� x• { ro 'm^a� .ems.,.
Reviewer/Inspector Name f t= ..
Reviewer/Inspector Signature: - Date: 7"/7- 97
T--
cc: Division of Water Quality, Water Quality Section, Facility Assessment Unit 4/30/97

State of North Carolina IqT
Department of Environment,
Health and Natural Resources A4140 •
Division of Water Quality
James B. Hunt, Jr., GovernorOL
Jonathan B. Howes, Secretary C) E H N FI
A. Preston Howard, Jr., P.E., Director
May 14, 1997
Douglas Bunting
Bunting Swine Farm - Cabell Farm
Rt 1 Box 144-B
Pinetops NC 27864
Subject: Removal of Registration
Facility Number 33-13
Edgecombe County
Dear Douglas Bunting:
This is to acknowledge receipt of your request that your facility no longer be registered as an animal waste
management system per the terms of 15A NCAC 2H .0217. The information you provided us indicated that your operation's
animal population does not exceed the number'set forth by 15A NCAC 2H .0217, and therefore does not require registration
for a certified animal waste management plan.
Under 15A NCAC 2H .0217, your facility is deemed permitted if waste is properly managed and does not reach the
surface waters of the state. Any system determined to have an adverse impact on water quality may be required to obtain a
waste management plan or an individual permit. You are reminded that a discharge of wastes to the surface waters of the state
will subject you to a civil penalty up to $10,000 per day.
Should you decide to increase the number of animals housed at your facility beyond the threshold limits listed below,
you will be required to obtain a certified animal waste management plan -prior to stocking animals to that level. Threshold
numbers of animals which require certified animal waste management plans are as follows:
Swine 250
Confined Cattle 100
Horses 75
Sheep 1,000
Poultry with a liquid wastes stern 30,000
If you have questions regarding this letter or the status of your operation please call Sue Homewood of our staff at
'[phone] ext 502.
Sincerely,
-SILOO
A. Preston Howard, Jr., P.E.
cc: Raleigh Water Quality Regional Office
Edgecombe Soil and Water Conservation District
Facility 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,
Health and Natural Resources
Raleigh Regional Office
James B, Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Mr. Douglas Bunting
Rt. 1 Box 144-B
Pinetops, NC 27864
IDEHNR
Division of Soil and Water Conservation
May 13, 1997
SUBJECT: Operation Review Summary
Bunting Swine Farm-Cabeli
Facility No. 33-13
Edgecombe County
Dear Mr. Bunting,
On April 29, an Operation Review was conducted of Bunting Swine Farm-Cabell,
facility no. 3-13. This Review, undertaken in accordance with G.S. 143-215.10D, was one of
two visits scheduled for all registered livestock operations during the 1997 calendar year.
The Division of Water Quality will conduct a second site inspection.
It was determined that no corrective actions are necessary as the result of this Review,
since waste was not being discharged to the waters of the State, and the animal waste
collection, treatment, storage and disposal systems were maintained and operated under the
responsible charge of a certified operator.
As discussed, the request for removal and confirmation of removal request forms were
delivered to the Division of Water Quality. Since the farm will be maintained below threshold
numbers, there should be no problem with processing the removal request. The Division of
Water Quality should send you a letter confirming this action.
The Division of Soil and Water Conservation appreciates your cooperation with this
Operation Review. Please do not hesitate to call me at 919/571-4700 ext. 208 if you have
any questions, concerns or need additional information.
Sincerely,
Marga t O'Keefe
Environmental Engineer I
uEdgecombe Soil and Water Conservation District
dy-y.Garretf;�pWa erg uaI y Re onal tSp erpvi5or
SWC-Re�1o'nat Fifes
3800 Barrett Drive, Suite 101, FAX [phone]
Raleigh, North Carolina 27609 Nif C An Equal Opportunity Affirmative Action Employer
Voice 919-571-4700 50% recycled/10% post -consumer paper

State of North Carolina
Department of Environment,
Health and Natural Resources
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Douglas Bunting
Bunting Swine Farm - Cabell Farm
Rt 1 Box 144-B
Pinetops NC 27864
FAFA
A Am�j Orin
1D E 1--I N R
November 13, 1996
SUBJECT: Operator In Charge Designation
Facility: Bunting Swine Farm - Cabell Farm
Facility ID#: 33-13
Edgecombe County
Dear Mr. Bunting:
Senate Bill 1217, An Act to Implement Recommendations of the Blue Ribbon Study
Commission on Agricultural Waste, enacted by the 1996 North Carolina General Assembly,
requires a certified operator for each animal waste management system that serves 250 or more
swine by January 1, 1997. The owner of each animal waste management system must submit a
designation form to the Technical Assistance and Certification Group which designates an
Operator in Charge and is countersigned by the certified operator. The enclosed form must be
submitted by January 1, 1997 for all facilities in operation as of that date. Failure to designate a
certified operator for your animal waste management system is a violation of 15A NCAC 2H
.0224 and may result in the assessment of a civil penalty.
If you have questions concerning operator training or examinations for certification, please
contact your local North Carolina Cooperative Extension Service agent or our office.
Examinations have been offered on an on -going basis in many counties throughout the state for
the past several months and will continue to be offered through December 31, 1996.
Thank you for your cooperation. If you have any questions concerning this requirement please
call Beth Buffington or Barry Huneycutt of our staff at 919/733-0026.
sincerely,
A. Preston Howard, Jr., . .,Director
Division of Water Quality
Enclosure
cc: Raleigh Regional Office
Water Quality Files
P.O. Box 27687, N!NW
�
Raleigh, North Carolina 2761 1-7687 rfC An Equal Opportunity/Affirmative Action employer
Voice 919-715-4100 50% recycled/100% post -consumer paper

State of North Carolina
Department of Environment,
Health and Natural Resources 1
Raleigh Regional Office a
James B. Hunt, Jr„ Governor p E H N
Jonathan B. Howes, Secretary FZ
DIVISION OF WATER QUALITY
August 20, 1996
Mr. C.B. Bunting
Route 1, Box 144B
Pinetops, North Carolina 27864
Subject: Compliance Evaluation Inspection
Swine operation
SR 1505
Facility No. 33-13
Edgecombe County
Dear Mr. Bunting:
On August 6, 1996, Mr. Eric Fleek from the Raleigh Regional Office
conducted a compliance inspection of the subject animal facility. This inspection
is part of the Division's continuing efforts to determine potential problems
associated with animal waste disposal systems.
Mr. Fleek's site visit determined that wastewater from your facility was
not discharging to the surface waters of the state. In addition, no manmade
pipes, ditches, or other prohibited conveyances (for the purpose of willfully
discharging wastewater) were observed. As a result, your facility was found to
be in compliance during this visit.
Effective wastewater treatment and facility stewardship are a
responsibility of all animal facilities. The Division of Water Quality is
required to enforce water quality regulations in order to protect the natural
resources of the State. Accordingly, illegal discharges of wastewater to surface
waters of the State are subject to the assessment of civil penalties and may also
result in the loss of deemed permitted status, requiring immediate submission of
a waste management plan.
This office would also like to take this opportunity to remind you that you
are required to have an approved animal waste mans ement plan by December 1997.
This plan must be Certified by a designated technical specialist or a
professional engineer. During the inspection, it was made known to the inspector
that this facility was nearly ready to. receive the animal waste management plan
from the Edgecombe MRCS staff. Please keep this office updated in regards to your
progress in obtaining this plan.
The Raleigh Regional Office appreciates your cooperation in this matter and
has noted the improvements made at this facility. If you have any questions
regarding your inspection please call Eric Fleek at [phone].
cc:
Sincerely,
Judy E. Garrett
Water Quality Supervisor
Edgecombe County Health Department
Edgecombe County Soil and Water Conservation District
Steve Bennett -Regional Coordinator, Division of Soil and Water Conservation
3800 Barrett Drive, Suite 101, � FAX [phone]
Raleigh, North Carolina 27609 Ntf An Equal Opportunity Affirmative Action Employer
Voice 919-571-4700 500% recycled/ 10% post -consumer paper

Facility Numberr-j3�
Division of Environmental Management
Animal Feedlot Operations Site. Visitation Record
Date: G (P
Time: l-_ ZOD- R
General Information:
Farm Name: CF-1 County: �dM
Owner Name: C_ tl n Phone No: 3 0
On Site Representative: L-1Z) Integrator: ---
Mailing Address: O
Physical Addre
Latitude: 1 1 Longitude: I 1
Operation Description: (based on design characteristics)
Type of Swine, No. of Ant' is L Type of Poultry No. of Animals Type of Cattle No. of Animals
Saw 1 CJJ (,Iv. f v a Layer 0 Dairy
Nursery Q Non -Layer ❑ Beef
❑ Feeder
OtherType of Livestock: Number of Animals:
Number of Lagoons: (include in the Drawings and Observations the freeboard of each'lagoon)
Facility Ian. pection:,
Lagoon n'
Is lagoon(s) freeboard less than 1 foot + 25 year 24 hour storm storage?: Yes ❑ No lac
Is seepage observed from the lagoon?: Yes ❑ No
Is erosion observed?: Yes ❑ No
Is any discharge observed? Yes ❑ N4
Q Man-made C1 Not Man-made
Cover Crop
Does the facility need more acreage for spraying?: /VPr4-2 Ye ❑ No ❑
Does the cover crop need improvement?: Y No ❑
( list the crops hich need improvement) ...
Crop type: ��j Acreage:
Setback Criteria
Is a dwelling located within 200 feet of waste application? �,`�� — Q Yes ❑ N�
Is a well located within 100 feet of waste application? (, Yes ❑ .Nc
Is animal waste stockpiled within 100 feet of USGS BIue Line Stream? Yes �N_ ❑���
Is animal waste land applied or spray irrigated within 25 feet of Blue Line Stream? Yes 4V ❑
AOI -- January 17,1996

Maintenance
Does the facility maintenance need improvement? Yes No ❑
Is there evidence -of past discharge from any part of the operation? Yes ❑ No
Does record keeping need improvement? Yes ❑ No ❑
Did the facility fail to have a copy of the Animal Waste Management Plan on site? Yes ❑ Noj
Explain any 'Yes answers: d r r `� _ �S r
4V t .�
�O V. a t'a� (,Cd W ac% �cf Ccv� to
r�
'T f-Ji _.
Signature:__ -� _ Date:
cc: FaciliryAssessment Unit Use Attachments if Needed
Drawings or Observations:
w-Nw
AOI -- January 17,1996
�.

NARRON, HOLDFORD. BABB, HARRISON & RHODES, P.A.
ATTORNEYS AND COUNSELORS AT LAW
204 NORTH TARBORO STREET
DRAWER 279
WILLIAM H. HOLDPOR4 WILSON, NORTH CAROLINA 27894,0279 TALMADGE L. NARRON
HENRY C. BASS. JR. TELEPHONE I919) 237-31S3 (11]25-1976)
R. WOODY HARRISON, JR.
THOMAS J. RHODES TELECOPIER 49)19) 243-1733
C. DAVID WILLIAMS. JR. OF COUNS44
I. JOE IVEY ROGER L. YOUNG
B. PERRY MORRISON, JR. December 27, 1995
WILLIAM L. O'QUINN, JR.
Ms. Judy Garrett
Mr. Eric Fleek
State of North Carolina
Department of Environment, Health & Natural Resources
3800 Barrett Drive, Suite 101
Raleigh, NC 27609
RE: Bunting Farms Swine Operation
SR 1505
Edgecombe County
NHBHR 95-657
Dear Ms. Garrett and Mr. Fleek:
This letter is simply an update on the progress of Bunting Farms in carrying out your suggested
improvements to the referenced operation. The tile in the dike at the lower end of the facility has now
been completely removed and the dike repaired with compacted soil so as to insure its integrity. In
addition, and as I have previously indicated, the pasture used for spray area has now been considerably
enlarged and, we believe, is of sufficient size to meet current requirements. We continue to await Mr.
Whitley's availability for the purpose of preparing and submitting a comprehensive management plan
and have been assured by him that he will be able to do so within the requested extension through the
end of January, 1996.
As always, we appreciate your cooperation. If you have any questions or comments about the
actions taken thus far, please feel free to call.
Sincerely,
F - R THE FIRM
HCBjr/jhu
cc: Bunting Farms
C %WPDATAIHCB\JU1003LT.HCB

NARRON, HOLDFORD, BABB, HARRISON & RHODES, P.A.
ATTORNEYS AND COUNSELORS AT LAW
204 NORTH TARBORO STREET
DRAWER 279
WILLIAM H. HOLDFORD
HENRY C. BABB, JR.
R. WOODY HARRISON, JR.
THOMAS J. RHODES
C. OAVIO WILLIAMS. JR.
I. JOE IVEY
B. PERRY MORRISON, JR.
WILLIAM L. O'OUINN, JR.
Mr. Eric Fleek
State of North Carolina
Department of Environment, Health
and Natural Resources
3800 Barrett Drive, Suite 101
Raleigh, NC 27609
WILSON, NORTH CAROLINA 27694-0279
TELEPHONE [phone]}59
TELECOPIER (9191 243-1733
RE: Bunting Farms Swine Operation
SR 1505
Edgecombe County
NHBHR 95-657
Dear Mr. Fleek:
December 20, 1995
TALMADGE L. NARRON
4192S-19761
O/ COUNSEL
ROGER- OUNG
D �
O�rIre
This is to confirm our telephone conversation of Wednesday morning, December 20, 1995, regarding the
efforts of Bunting Farms to comply with the requests of your Department as set out in the letter of Mr. Preston
Howard, Jr., dated November 29, 1995. We have previously communicated the intention of Bunting Farms to
comply with all of the requests of DEHNR with regard to this facility, and specifically to comply with the
requests as contained in the November 29 letter. With reference to the submission of an approved animal waste
management plan, however, we are encountering some delays which are simply beyond our control. We had
originally anticipated that Mr. A. B. Whitley would review the facility and prepare the plan. Only recently,
however, Mr. Whitley has indicated that he could not complete that effort until the end of January, 1996. In an
effort to comply with the requests of your Department within the time frame stated, Bunting Farms retained the
services of Appians Consulting Engineers, of Rocky Mount. Mr. Burke Evans of that office has indicated to us
that although Appians could perform most of the services necessary to the completion of the management plan,
we would still be required to get Mr. Whitley's approval of the plan and, specifically, the issues relating to the
certification of the existing lagoon on the property. That being the case, we are still now confronted with Mr.
Whitley's time frame of availability; i.e., the end of January, .1996. Given that we still need Mr. Whitley's
review and approval, Bunting Farms has elected to wait for Mr. Whitley to develop the entire plan. This creates
an absolute impossibility for Bunting Farms, however, to comply with the original time deadline as
communicated in your letter of November 29.
Obviously we are making a good faith effort to comply and it is our intention to in fact comply with your
requests as soon as we possibly can. We are requesting, therefore, that Bunting Farms be granted an extension of
time within which to obtain an approved management plan. If this request causes your department any concern
we would appreciate hearing from you in order that we might discuss whatever alternatives are available.
Very rs
THE FI
HCBjr/dh
cc: Bunting Farms
Mr. Burke Evans
D:\WPDATA\HCB\DH106LT.HCB

NARRON, HOLDFORD, BABB, HARRISON & RHODES, P.A.
ATTORNEYS AND COUNSELORS AT LAW
204 NORTH TARBORO STREET
DRAWER 279
WILLIAM H. HOLOFORD WILSON, NORTH CAROLINA 27894-0279
HENRY C. BABB, JR.
TELEPHONE [phone]
R. WOODY HARRISON, JR.
THOMAS J. RHODES
TELECOPIER [phone]
C. DAVID WILLIAMS. JR.
I, JOE IVEY
B. PERRY MORRISON. JR.
WILLIAM L. O'OUINN, JR,
December 11, 1995
Ms. Judy E. Garrett, Water Quality Supervisor
Division of Environmental Management
Department of Environment, Health and
Natural Resources
3800 Barrett Drive, Suite 101
Raleigh, NC 27609
RE: Bunting Farms
Dear Ms. Garrett:
TALMADGE L. NARRON
(1925-1976)
OF COUNSEL
ROGER L. YOUNG
P�-
This is to confirm our telephone conversation of Thursday, December 7, regarding the letter from
your office to Bunting Farms dated November 29, 1995. It is my understanding from that conversation
that your department, as a result of our most recent visit to the site, determined that there was in fact
some animal waste in the pond, that there is not sufficient land for the site and that there is too much
slope to the sides of the pond.
As we indicated when we discussed these issues on the site some several weeks ago, Bunting
Farms is addressing all of these concerns and believes it will have them all remedied in a satisfactory
fashion in the very near future. In fact, approximately two and one-half additional acres at the site have
been cleared and seeded and are now in use. It is our belief that this additional acreage, when combined
with the existing, meets any and all regulatory requirements. In order to confirm that belief, however,
we are in the process of having an approved animal waste management plan completed. We anticipate
that it will certify that the site is in compliance with all regulations and, certainly, it is our intent that this
be done. We have been attempting to get the plan completed since our mutual visit to the site some
weeks ago, but, as you are aware, it is very difficult to schedule any of the individuals qualified to
perform the service. Nevertheless, we have every expectation that we have it completed in the near
future and will forward it to your department for review.
As always, we appreciate your continuing cooperation.
Sincerely,
FOR THE FIRM '
HCBjr/dh
cc: Bunting Farms
D :1 W PDATAI H CB IDH 105 LT. H C B

SION OF ENVIRONMENTAL MANAGEMENT
ceeo L.abarntory Report r Water QwrBty
;C�\y�IGN WE] SAMPLE TYPE
COUNTY EDGECOMBE PRIORITY
RIVER BASIN: ❑ AMBIENT Lj QA ® STREAM EFFLUENT
REPORT TO RRO Regional Office ❑ COMPLIANCE ® CHAIN OF CUSTODY LAKE INFLUENT
Other : ® EMERGENCY ❑ ESTUARY
COL LECI'OR(S) I LEEK 1
Estl®tM ROD Range: Station Location: CB BUNTING SWINE
Seed: Chlorinated: N Remarks: SR 1505 STREAM
Sbdbo / Ili" Begin (7ylormld* Date End (yylmmldd) Time Begin Time End I Depth - DM, DR, DBM Valve Type - A,11, L CampodwT, S, B Sample Type
1 12/8195 G
X
BOD 310 NO VALUE mg/I,
COD High 340 mg/L
COD Law 335 1119/1-
X
Colifarm: MF Feea1316 i 6 C 10 110Dm1
Cdiform: MFToW 31504 110ung
Caliform: tube Fecal M615 !loom]
Conform: Fecal 31673 1100m1
Residue: Tota1500 mg/L
Vdau7e 5015 mg/L
Fixed 510 m91L
Residue: Suspencled 530 mg/L
Volatile 535 mg1L
Fixed 540 mg/-
H 403 6.2 unks
Acidity to pH 4.5 436 m
Ac' . to pH &3 435 mg/L
AIWinity to pH 8.3 415 rwL
Alkalouty to H 4.5 410
TOC 680 1118/L
Turbidity 76 NTU
COMMENTS :
C hkwide 940 mg/L
Chi a: Tri 32217 ug1L
Qd a: Carr 322D9 !a
ytin a 322i3
Color, True 80 a-u.
Color: (pH ) 83 H= C.U.
Color: pH 7.6 82 c.u-
Cyanide 720 mg/L
Fluoride 951 mg/L
E naWchyde 71&0 9g1L
Grease and Oils 556 mg1L
H.,Incss Tow 900 21191L
iF' Card. 95 uMhoslcm2
MBAS 3g260 mg/L
Phenols 32730 ugf
Sulfate 945
Sidlie 745 111911-
Baron
Coliform Total Tube "1100 ml-
8
NH3 as N 610
6.4
mg/L
X
TKN an N 625
7.4
Tri
X
NO2 plus NO3 as N 630
2.4
mg/L
X
P: Total as P M5
4.3
m91L
PO4 as P 70507
mg/L
P: Dissolvod as P 666
m91L
K-Potassium
mg/L
Cd- Cadmium 1027
Eli
Cr-Chromium:Tote] 1034
ug/L.
Or 1D42
Ni-Nickel I067
w lad 1051
ug/L
2o- Zinc 1092
ug1L
V-Vanadium
ug/L
Ag- Silver 1077
u911-
Al- Aluminum 1105
ug1L
Be- lium 1012
ug/L
Ca- Ca]cnarr 916
mi
Co- Cobalt 1037
ug/L
Fe- Iran 1045
ugll
Li -Lithium 1132 ug/L
Mg- Magwsi n 927 nw&
Ma 1055 ug/L
Na- Sodiwrt 929 mg/L
Arsenic:Total1002 ugrL
Sr- Selenium 1147 ug/L
Hg- ME2m 7190D ugll.
Ba Barium
OWnoddoriw Pesticides
OrpnThoWhams Pesticides
Acid Herbicides
BascfNeutra1&A6d Extractable Organics
TPH Diesel Range
Purgmble (VOA batik 'd)
TPH Gasoline Range
TPHIBTEX Gasoline Range
Pllytoptuddon

DIVISION @Q ENVIRON�M�Ef�NTAL MANAGEMENT WATER QUALITY FIELD -LAB FORM (DM1)
COUNTY- 0� v/l b'�_ k �, e
PRIORITY a $�ISAiMP TYPE
e... r ii �, _WAG)' RNFlI BASIN � A � y ` L � �
REPORT TO: ARO FRO MR RR aRO WIRO WSRO TS ❑AMBIENT ❑ QA ST E%K '• FLUENT
AT BM ❑COMPLIANCE [LkH_AIW ❑ LAKE ❑ INFLUENT
Other P—
OF CUSTODY
Shipped by: Bus Courier, Stal , Other I —EMERGENCY ❑ ESTUARY
For Lab Use ONLY
Lab Number:
For Lab Use ONLY
Lab Number:
Date Received: L ;2—t ­i�Time:
Rec'd by:
From: Bus-Cou ' --Hand Del
DATA ENTRY B
CK:
DATE REPORTED_
COLLECTOR(S): 4 a • �} %� % /
Estimated BOD Range; 0 5/5 25/25-65/40 130 or 100 plus STATION LOCATION: ` `�tJ' I 1 y ' k {h/ j \ [ �Oz I
Seed: Yes ❑ No❑ Chlorinated: Yes ❑ Nct E] REMARKS:
Station Date Begin (yy/mm/dd) Tlme Begin Date End Time End Depth DM DB DBM Value Type Composite Sample e
1 %5 Q A H L T S R C G) GNXX
1
BOD5 310 mg/I
2
COD High 340 mg/1
3
COD Low 335 m9/1
4
Collform: MF Fecal 31616 /100m1
5
Coliform: MF Total 31504 /looml
6
Collform: Tube Fecal 31615 /100m1
7
Coliform: Fecal Strep 31673 /loom]
8
Residue: Total 500 mg/I
9
Volatile 505 mg/I
10
Fixed 510 mg/1
11
Residue: Suspended 530 mg/I
12
Volatile 535 mg/I
13
Fixed 540 mg/1
14
PH 403 units
15
Acidity to pH 4.5 436 mg/1
16
Acidity to pH 8.3 435 mg/I
17
Alkalinity to pH 8.3 415 mg/I
18
Alkalinity to pH 4.5 410 mgA
19
TOC 680 mg/l
20
Turbidity 76 NTU
Chloride 940 mg/I
Chi a: Tri 32217 ug/1
Chi a: Corr 32209 ug/1
Pheophytin a 32213 ug/1
Color: True 80 Pt -Co
Cofor:(pH ) 83 ADMI
Color: pH 7.6 82 ADMI
Cyanide 720 mg/I
Fluoride 951 mg/I
Formaldehyde 71880 mg/I
Grease and Oils 556 mg/1
Hardness Total900 mg/I
Specific Cosid. 95 uMhos/em2
MBAS 38260� mg/I
Phenols 32730 USA
Sulfate 945 mg/l
Sulfide 745 mg/1
NH3 as N 610 mg/f
TKN as N 625 mg/1
NO2 plus NO3 as N 630 mg/I
P. Total as P 665 mg/1
PO4 as P 70507 mgA
P: Dissolved as P 666 mg/f
Cd•Cadmium 1027 ugA
Cr-Chrulufum:Total1034 ugA
Cu-Copper 1042 ug/I
NI -Nickel 1067 ug/1
Pb-Lead 1051 ug/I
Zn-Zinc 1092 ug/I
Ag-Sliver 1077 ug/l
A] -Aluminum 1105 ug/1
Be -Beryllium 1012 ug/I
Ca -Calcium 916 mgA
Co -Cobalt 1037 ug/1
Fe -Iron 1045 ugA
LI-Lithium 1132
ug/I
Mg-Magneslum 927
mg/l
Mn-Manganese 1055
ug/I
Na-Sodium 929
mg/I
Arsenic:Ibtal 1002
ug/1
Se -Selenium 1147
ug/I
Hg-Mercury 71900
ugA
Orgattochlorine Pesticides
Otga31oph0spl0m9 Pesticides
I I Acid herbicides I
I} Base/ Neutral Extractable Organics
Acid Extractable Organics
Purgeable Organics (VOA bottle reg'd) I
I lPhytoplankton
Sampling Paint 76
Conductance at 25 C
Water Temperature 40
A.O. mg/1
pH
Alkalinity
Acidity
Air Temperature (C)
PH8.3 PH 4.5
p114.5 PH 8.3
2
94
to
300 1
400 1•
82244 L 431
82243 182242
20 _
Salinity
Precipltion (in/day)
Cloud Cover X
Wind Direction (Deg)
Stream Flow Severity
Turbidity Severity
Wind Velocity M/H
can Stream Depth ft.
Stream Width It.
480.
45
32
36
1351
1350
35
64
4

1
NO.
4
ZV Division of Environmental Management
CHAIN OF CUSTODY RECORD
For Investigation of ��� f3U��) illy 0
Samples collected and DMI
forma completed
by:
Lab Orilq
Lab'No.
Station.
No.
Station Location
Date
Time
No. of
Bottles
0
<10
F
Relin ishe by ignatux
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Re
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Method of Shipment:
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Type and Condition:
Seal by:_--__
Lock b
Broken b :
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YAM usE ONLY
P om
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Container 8
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Received by
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`
i

Division of Environmental Management
CHAIN OF CUSTODY RECORD
For Investigation of
5 h 1J o_
ISamples collected and DMI
forms completed
by:
Lab Orily
Lab'No.
Station.
No.
Station Location
Date
Time
No. of
Bottles
RelinWish by. i nature):
Re
by(
Lure ;
D / imp,
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Rec
Rel
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by
Rel
Rec
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Method of Shipment: /C,'i
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Securit Ine and Condition:
Seal b
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Broken by:
22en b :
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From —■Containers.:
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State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
MR. C. B. BUNTING
C. B. BUNTING SWINE FARM
ROUTE 1 BOX 144 B
PINETOPS, NC 27864
IT
4 K?FA
LT. •
� J
� `rT
C)EHNF1
November 29, 1995
Subject: Notice of Violation # 95-27
Notice of intent to Revoke Deemed Permit
C.B. Bunting Swine Farm
Farm Number 33-013
'iEdje_ combe Co`u_nty—
Dear Mr. Bunting:
A� O
You are hereby notified that, having been deemed permitted to have a nondischarge 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 15, 1995, Mr. Eric Fleck of the Raleigh Regional Office conducted an re -inspection at
your facility that revealed wastewater discharging to Deep Creek (classified C NSW) via a
manmade conveyance (pipe). Furthermore, Mr. Fleek also noted that according to a U.S.
Department of Agriculture Soil Conservation Service map, your newly constructed lagoon (and the
uncontained waste located adjacent to it) is located within an intermittent unnamed tributary of Deep
Creek.
In accordance with the requirements of NCAC 211.0213, you are hereby given notice that sixty
(60) days following your receipt of this letter, the Division of Environmental Management intends
to revoke your permit unless the following conditions are completed:
1. Immediately eliminate the discharge of wastewater or correct the violation.
2. Make any modifications needed to ensure there will be no future discharges.
3. Submit an approved animal waste management plan and have the attached certification form
completed. One copy of the plan must be sent to your local Soil and Water Conservation
District. The certification form and two (2) copies of your plan must be returned to the address
below:
Division of Environmental Management
Water Quality Section Operations Branch
F.O. Box 29535
Raleigh, NC 27626-0535
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

Failure to comply with the above conditions will result in permit revocation and therefore, the
existing animal waste management system serving your animal operation will be in operation
without a permit as required by North Carolina General Statute 143-215.1.
Your approved animal waste management plan must explain how you will collect, store, treat and
land apply your animal waste in an environmentally acceptable manner. To assist you in the
development of this plan and to provide the required certification that the plan is acceptable, you
should contact your local agricultural agencies such as the Soil and Water Conservation District,
the USDA Natural Resource Conservation Service, the North Carolina Cooperative Extension
Service or a technical specialist designated pursuant to the rules adopted by the Soil and Water
Conservation Commission.
If we have not received the requested animal waste management plan and certification within 60
days of receipt of this letter or if there are additional discharges to the surface water a civil penalty
of up to $10,000 may be assessed and you may be required to apply for an individual
nondischarge permit from the Division. This permit, if issued, will contain monitoring and
reporting requirements determined to be necessary by the Division.
Although we will make every effort to work with you in correcting the problems found at your
facility, please be advised that nothing in this letter should be taken as preventing the Division from
taking appropiate enforcement actions for either these violations or other past or future violations.
If you have any questions concerning this matter please do not hesitate to contact either Judy
Garrett, Water Quality Regional Supervisor for our Raleigh Regional Office at [phone] or
Mr. Shannon Langley at [phone], ext. 581.
Sincerely,
.�4A. Preston Howard, Jr., P.E.
ATTACHMENTS
cc: CRegi6n-MWater_Quality Supervisor
Edgecombe County Soil and Water Conservation District
Steve Bennett - Regional Coordinator, NC DSWC
Compliance/Enforcement File
Edgecombe County Health Department

NARRON, HOLDFORD, BABB, HARRISON & RHODES, P.A.
ATTORNEYS AND COUNSELORS AT LAW
204 NORTH TARBORO STREET
DRAWER 279
WILLIAM H. HOLDFORD
HENRY C. BABB, JR,
R. WOODY HARRISON, JR.
THOMAS J. RHODES
C. DAVID WILLIAMS, JR.
1. JOE IVEY
B. PERRY MORRISON, JR.
W{LLIAM L. O-OUINN, JR.
WILSON. NORTH CAROLINA 27894-0279
TELEPHONE [phone]
TELECOPIER (9191 243-1733
October 10, 1995
Ms. Judy Garrett
Mr. Eric Fleek
State of North Carolina
Department of Environment, Health
& Natural Resources
3800 Barrett Drive, Suite 101
Raleigh, NC 27609
RE: Bunting Farms Swine Operation
SR 1505
Edgecombe County
N1 BHR 95-657
Dear Ms. Garrett and Mr. Fleek:
TALMADGE L, NARRON
(1925-19745)
OF COUNS6l
ROGER L. YOUNG
3013�0 ltlf�a0l`J�19 WOl�l�g 11NH70
r
I first want to express my personal appreciation and that of Bunting Farms for your courtesy in meeting
with us on this site on Friday, October 6, 1995. In my view, the meeting was very helful in establishing a mutual
understanding of the necessary future course of action for the site. As you suggested, Bunting Farms will
immediately begin the removal of the water standing on the site and will be careful to do so in a fashion consitent
with the spray area which is available, Additionally, as soon as weather will permit, we will undertake a
complete reevaluation of the dam at the lower end of the property to insure its integrity. Those items being
properly completed, it is our understanding that any further alterations or corrective actions should await the
recommendations of the management plan being formulated by Mr. Whitley.
Again, we are most grateful for your cooperation and appreciate your providing us with an opportunity to
address any outstanding concerns which you might have had. As we indicated, we certainly invite you to call in
the future with any additional questions or suggestions which you might have. It is our intention to implement
an effective management plan throughout Bunting Farms and we would welcome your participation and input
into that process.
Since ely,
Gr-"
9 a-
IRM
HCB/apb
CC: Bunting Farms
D:1 WPDATAViCMAB 174LT.HCB

DIVISION OF ENVIRONMENTAL MANAGEMENT WATER QUALITY FIELD -LAB FORM (DM1)
COUNTY
PRIORITY
SAMPLE PE
0
RIVER BASIN G✓"
❑AMBIENT
❑ QA
STREAM
❑
EFFLUENT
REPORT TO: ARO FRO MR
R WaRO WIRO WSRO TS
AT BM
❑
❑
❑
❑
COM IANCE
CHAIN
LAKE
INFLUENT
Other OF CUSTODY
Shipped by: Bus Courier to Other ,�} .015�ERGENCY ❑ ESTUARY
COLLECTOR(5): P CC_ Gr foahNQ.L1
Estimated HOD Range: 0-5/5 5/25-65/40-130 or 100 plus STATION LOCATION:
Seed: Yes ❑ No Chlarfaated- yes No ❑ REMARKS:
97— R.I. II.. nN1 V
Lab Number:
l 2,Y
Date Received:Lo�C%j
Time.•l.'���?�
�7
Rec'd b ; T
From: Bus-Couri -H nd Del
DATA ENTRY BY:
DATE REPORTED:
--I bi
Station'
19-IS
Date Begin (yy/mm/did)
C)U�
Time Beg
�� Sin
Date End
Time End
Depth DM DR DBM
Value Type Cvinposite Sam e T
A H L \�.T?,S,B� ; \� G GNXX
GODS 310 7;E mg/I
2
COD High 340 m9/1
3
COD Low 335 mg/1
4
Coliform: MF Fecal 31616 /100ml
5
Coliform: MF Total 31504 /100ml
6
Coliform: Tube Fecal 31615 /100ml
7
Coliform: Fecal Strep 31673 /100ml,
8
Residue: Total 500 mg/i
9
Volatile 505 mg/i
10
Fixed 510 mg/1
1
Residue: Suspended 530 mg/I
12
Volatile 535 mg/I
I3
Fixed 540 mg/I
14
pl1 403 (/ units
15
Acidity to pH 4.5 436 mg/1
16
Acidity to pH 8.3 435 mg/1
17
Alkalinity to p11 8.3 415 mgA
18
Alkalinity to pH 4.5 410 mg/I
19
TOC 680 mg/I
20
Turbidity 76 NTU
Chloride 940 mg/I
Chl a: Tri 32217 ug/1
Chi a: Corr 32209 ug/1
Pheophytin a 32213 ug/1
Color: True 80 Pt -Co
CoIor:(pH ) 83 ADM[
Color: pH 7.6 82 ADMI
Cyanide 720 mg/i
Fluoride 951 mg/l
Formaldehyde 71880 mg/l
Grease and Oils 556 mg/1
Hardness Total900 mg/I
Specific Cond. 95 uMhus/cm2
MBAS 38260� moil
Phenols 32730 ug/i
Sulfate 945 mg/1
Sulfide 745 mg/I
N113 as N 610 7 mg/1
vC�
TKN as N 625 mgA
NO2 plus NO3 as N 630 Q,S mg/f
P: Total as P 665 -5� mg/]
PO4 as P 70507 mg/1
P: Dissolved as P 666 moil
Cd-Cadmium 1027 ugA
CrChromlum Total 1034 ugA
Cu-Copper 1042 ug/1
NI -Nickel 1067 ug/l
Pb-Lead 1051 u9/1
Zn-Zlnc 1092 ug/l
Ag ilver 1077 roil
AI -Aluminum 1105 ug/I
Se-Berylllum -1012 ug/I
Ca-Calclum 916 mgA
Co -Cobalt 1037 ug/I
Fe -Iron 1045 . ugA
Li-Lf ilil um -14 32 ug/I
1lYV" !
MgdHagnesfum 927 mg/I
Mn-Manganese 1055 ug/I
Na-Sodlurn 929 mg/l
Arsenic:Total 1002 ug/l
Se-Selenlum 1147 ugA
Hg-Mercury 71900 ug/1
Organochlorine Pesticides
Organophosphorus Pesticides
Acid Herbicides
Base/ Neutral Extractable Organics
Acid Extractable Organics
Purgeable Organics (VOA bottle reg'd)
Phytoplankton
Sampling Point X
Conductance at 25 C
Water Temperature
D.O. m9A
pH
Alkalinity
Acidity
Air Temperature (C)
pH 8.3 pH 4.5
pH 4.5 pil 8.3
2
94
10
300 10
400 if
82244 1431
82243 182242
20
Salinity %
Precipltlon (in/day)
Cloud Cover %
Wind Direction (Deg)
Stream Flow Severity
Turbidity Severity
W Ind Velocity M/H
can Stream Depth It.
Stream Width it.
480
45
132
36
1351
1350
35
64
4
J

For Investigation of
Division of Environmental
CHAIN OF CUSTODY RECORD
� ,a l�D j
t2 lg ; �1
FtN Gh' fi(G,f� I n ..
Samples collected and
DMI forms
completed
by:
b Orily
Lab'No.
Station.
No.
Station Location
Date
Time
No. of
Bottles
5?,rt72
aS
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3
Reli iahed by igna
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Method of Shi meat:
4"
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Security a and Condition: Lock
b :
b
Broken b :
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T AL TTCV MATTV
Lab No.
From Throe h
No.
Containers
Analysis
Relin uished b
Received by
Date Time

NARRON, HOLDFORD, BABB, HARRISON 8c RHODES, P.A.
ATTORNEY5 AND COUN5ELORS AT LAW
204 NORTH TAR90RO STREET
DRAWER 279
WILLIAM H. HOLDFORD WILSON, NORTH CAROLINA 27894-0279 TALMADGE L. NARRON
HENRY C. BABB, JR. TELEPHONE [phone]IS3 (1925-1976)
R. WOODY HARRISON, JR.
THOMAS J. RHODES TELECOPIER (919) 2.43-1733
C. DAVID WILLIAMS, JR.
O/ COUNSEL
I. JOE IVEY ^/�
15, PERRY MORRISON, JR. September 20, 1995 ROGER L. YOUNG
WILLIAM L. O'OUINN, JR. ,
VIA FACSIMILE AND U.S. MAIL
2 1
Mr. Kenneth Schuster `' SEPl f9�r�
Regional Supervisor
N.C. Department of Environment, AtElC17 f, ,d„r +C
Health & Natural Resources "" -- _ , J
3800 Barrett Drive, Suite 101
Raleigh, NC 27601
RE: Bunting Farms Swine Operation
S.R. 1505
Edgecombe County
NHBHR 95-657
Dear Mr. Schuster:
Thank you for your letter of September 7, 1995, and for the opportunity to address the concerns
expressed. It is the Buntings' intention to operate their facility in compliance with the law and with the
best available management practices. Because of their commitment to quality management practices
they take very seriously any questions or concerns which arise, and this response is submitted after a
careful and thorough review of the referenced facility. In your letter you have raised a number of
issues, but prior to our specific responses and by way of general information, we believe that the basic
premise of the letter (i.e., that there is on the facility an illegally discharging lagoon) is incorrect. The
"lagoon" is not a lagoon at all. It was constructed and functioned g& as a watering pond for cattle.
Additionally, the "manmade conveyance (pipe) behind the new lagoon's dike" is not an outlet pipe; it is
an inigi pipe designed to collect surface water and channel it into the watering pond at its upper end.
The watering pond is located in a cow pasture with cows in the pasture and it has been in existence for
less than a month. Our farm manager had the pond dug during August, 1995, while he had access to a
drag line which was on the farm making other improvements. The pipe was placed there at the same
time in anticipation of constructing a path and was installed in order to allow runoff water (whenever it
collected in that depression) to run into the pond. No water could be discharged from the pipe since it is
located at the higher end of the pond.
By way of specific response to the issues raised in your letter, however, we would offer the
following:
1. Quantities of "uncontained waste". In all candor, we are somewhat uncertain as to the
appropriate response to this issue because we are not aware of the existence on the site of any
uncontained waste, whether adjacent to the watering pond or not. We would be happy, however, to

Mr. Kenneth Schuster
September 20, 1995
Page 2
review the site with Mr. Fleek to determine the nature of this problem and resolve it according to your
recommendations.
2. The existence of a "newly constructed lagoon". As we have indicated, the "lagoon" is
actually a watering pond for cattle and was (until the receipt of your letter) functioning in that manner.
It is located in a cattle pasture with cattle present and has never been utilized as a lagoon for animal
waste retainage purposes.
3. Location in an "intermittent unnamed tributary of Deep Creek". AIthough your letter
acknowledges that the area where the pond is located is at most an "intermittent" tributary of Deep
Creek, we are unaware that this slight depression could fairly be characterized as a "tributary" and we
are certain, however it should fairly be described, that it cannot flow into Deep Creek. The depression
(even before the construction of the pond) was dammed at its lower end and the dam is still in existence
and is completely intact. Further, beyond the dam at its lower end is several hundred feet of existing
woods land before reaching what actually is an existing tributary of Deep Creek. The Buntings have not
observed any runoff through or around this dam, either before or subsequent to the construction of the
watering pond, since they have owned the property (approximately 1989), and they are certain that there
has been no flow through that dam in the few weeks since this pond has been constructed.
4. The existence of a "manmade conveyance (pipe) behind the new `lagoons' dike". As we
have stated, the pipe did (until your letter) exist; but it was = an outlet pipe behind a "lagoon." It was
an inlet pipe to channel surface water flow into the watering pond and to permit the construction of a
path at that point.
5. Wastewater discharge into Deep Creek. Since we were not present when Mr. Fleek made
his inspection, we are unsure what he observed which could constitute a discharge of any type into Deep
Creek. We are certain, however, that there could be no discharge from the described pipe (since the
water flowing through it flows LrU2 the pond) and that there is no wastewater to be discharged (since the
water is only surface water impounded for cattle and the pond is not used for animal waste containment).
6. Discharge violation of G.S. 143-215.1(a). There has been no discharge of any kind from
the watering pond. As indicated, the pipe which has been described is at the upper end of the pond and
serves as the inlet into the pound, not as a discharge outlet. Further, the pond is dammed completely at
its lower end and the integrity of the dam remains intact such that there is no discharge at that end.
Thus, to the best of our knowledge, there has been no violation of the referenced statute.

Mr. Kenneth Schuster
September 20, 1995
Page 3
7. Conveyances for the purpose of willful discharge in violation of G.S. 143-215(e). This
statute prohibits the construction of any conveyance "... for the purpose of willfully discharging
pollutants to the waters of the State." As stated, the described pipe was not constructed to serve as a
conveyance for discharging at all, nor has it in fact served that purpose. It was only in place for a few
weeks and, during that time, served only as an inlet into the pond.
In summary, we believe that the conclusions set out in your letter are based on an unintentional
misapprehension of the facts as they exist on the subject farm, especially as to the direction of flow of
surface water in that location. Given that the surface water flows into and not out of the watering pond,
and given further that the pond only serves as a watering location for cattle, we respectfully contend that
there have no violations of law or regulatory policy. Most importantly, we are absolutely certain that
there have been no willful discharges of pollutants into the waters of the State. We believe that a
reexamination of the site would confirm our position and we would be more than happy to arrange and
participate in such an inspection.
Nevertheless, and even though we strongly believe that no violations have occurred, we have
taken complete corrective action on a voluntary basis. That is, the pond has now been completely
eliminated and leveled and the pipe has been removed. This was done on September 10, 1995. We
believe this action completely eliminates even the perception of a violation, but we would be happy to
take any additional steps which a subsequent inspection might determine necessary. In fact, we gather
from Mr. Fleek's most recent comments to the press The Daily Southerner, Monday, September 18,
1995) that he has again inspected the facility and confirmed the corrective action.
In response to your inquiry about Oar ciurent waste rnaragcrnent practices, there is in fact an
actual waste retention lagoon located on this farm but at some distance from the watering pond which
was the subject of your letter. That lagoon is irrigated into a field of approximately three and one-half
(3'/2 ) acres sewn in a mixture of wire and bermuda grass. We utilize a hard reel with a Nelson 200 gun
from a PTO pump. We also use solid aluminum pipe with sprinklers and a PTO pump, as well as a
small electric pump and sprinklers. The lagoon is pumped on average every six weeks (depending on
weather) or when the water level reaches within two feet of its dike, whichever first occurs. There are
presently 243 hogs on the facility.
In addition to the specific actions which we have taken to eliminate the concerns you have
expressed, Mr. A. B. Whitley, Soil and Water Conservation agent for Edgecombe County, is scheduled
to start the development of a comprehensive waste management plan for this facility on September 26.
We share the concern of the State that our facility, as well as all others in the swine industry, be operated
in a fashion so as to protect the environment and people of North Carolina. We are committed to that

Mr. Kenneth Schuster
September 20, 1995
Page 4
goal and will be happy to work with your department in that regard. We hope this response is sufficient
to address all of the concerns raised in your letter, but if any further information is necessary please let
us know.
Ve truly yours,
,2
my b
Counsel for Bunting Farms
HCBjr/jhu
CAW PDATAIHCB11U945LT. HCB

DIVISION OF ENVIRONMENTAL MANAGEMENT
RALEIGH REGIONAL OFFICE
September 7, 1995
M E M O R A N D U M
To: Dianne Williams Wilburn
Supervisor, Facility Assessment Unit
Through: Kenneth Schuster, P. E.�
Regional Supervisor
From: Judy Garrett
Regional Water Quality Supervisor
Prepared By: Eric Fleek �
F ec Environment hnician
Subject: Notice of Violation
Loss of Deemed Permitted Status
C. B. Bunting
SR 1505
Edgecombe County
Please find attached a letter for signature concerning the above
referenced swine facility. This facility was re -inspected by DEM
and NRCS staff on August 15, 1995 and was found to have
discharged animal waste into Deep Creek which are classified as
C-NSW waters of the Tar -Pamlico Basin. It should also be noted
that the newly constructed lagoon (and adjacent uncontained
waste) is actually located in an intermittent unnamed tributary
of Deep Creek (please see attached maps and photos).
If you have any questions concerning this facility please contact
Eric Fleek at the Raleigh Regional Office.

State of North Carolina
Department of Environment,
Health and Natural Resources 4
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary E H N FR
A. Preston Howard, Jr., P.E., Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. C. B. Bunting
Route 1, Box 144B
Pinetops, North Carolina 27664
Subject: LOSS OF DEEMED PERMITTED STATUS
NOTICE OF VIOLATION
As Per 15 A NCAC 2H.0217 (a) (1)
SR 1505
Edgecombe County
Dear Mr. Bunting:
Animal operations in the State have been deemed permitted by
the Division of Environmental Management in accordance with Title
15A of the North Carolina Administrative Code, 2H, Rule .0217. An
individual non discharge permit is not required if certain
criteria are met. A major requirement to be deemed permitted is
that there must not be a discharge of any wastewater from the
operation to the waters of the State.
This letter transmits a Notice of Violation and notification
that your animal operation has been found discharging wastewater
to the surface waters of the State and is therefore no longer
deemed permitted as a non discharge facility under 15A NCAC 2H
.0217. Therefore the existing wastewater treatment system serving
your animal operation is currently being operated without a
permit as required by North Carolina General Statute 143-215.1.
On August 15, 1995, Mr. Eric Fleek of the Raleigh Regional
Office conducted a re -inspection of your facility that revealed
wastewater discharging to Deep Creek (classified C-NSW) via a
manmade conveyance (pipe). Furthermore, Mr. Fleek also noted that
according to a U. S. Department of Agriculture Soil Conservation
Service map, your newly constructed lagoon (and the uncontained
waste located adjacent to it) is located within an intermittent
unnamed tributary of Deep Creek.
If you wish to be reconsidered for coverage by the deemed
permitted provision of the Rule, you must: 1) immediately
eliminate the discharge of wastewater; 2)make any modifications
needed to ensure there will be no future discharges; 3)send in an
approved animal waste management plan by completing the attached
certification form. This form and a copy of your plan must be
returned to:
P.O. Box 29635, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportuntty Affi►mahve Action Employer 50% recycled/ 10% post -consumer paper

' C. B. Bunting
Loss of Deemed Permitted Status
Page 2
Division of Environmental Management
Water Quality Section Planning Branch
s P. 0. Box 29535
Raleigh, N. C. 27626-0535
Your approved animal waste management plan must explain how
you will collect, store, treat, and land apply your animal waste
to the land in an environmentally acceptable manner. To assist
you in the development of this plan and to provide the required
certification that the plan is acceptable, you should contact
your local agricultural agencies such as the Soil and Water
Conservation District, the USDA Natural Resource Conservation
Service, or the North Carolina Cooperative Extension Service.
If you have any questions concerning this information,
please call Ms. Judy Garrett, Water Quality Regional Supervisor
at [phone] or Ms. Dianne Williams Wilburn of our Central
Office staff at [phone], ext.232.
Sincerely,
A. Preston Howard, Jr., P.E.
cc: Regional Water Quality Supervisor
Edgecombe Soil and Water Conservation District
Edgecombe County Health Department
Steve Bennett -Division of Soil and Water Conservation
Planning Branch
Operation Branch
RRO-File Copy
Central Office -Water Quality

Inspection Form for Animal Operations
1. Inspection Date: August 15, 1995
2. Regional Office: RRO
3. Name of owner of property: Mr. C..B. Bunting
Current Address: C. B. Bunting
Route 11, Box 14 4 B
Pineta;•?s, North Carolina 27864
4. Name of operator: Mr. C. B. Bunting
5. Description of facility location: SR 1505, off 122 South
near Speed, N. C.
6. Date facility began operation: Approximately 10-15 years ago
7. Date of last inspection: July 17, 1995
8. Has facility registered with DEM: Yes
9. Does facility have approved animal waste plan: No
10. Has facility received a CAFO designation: No
11. Operation type: Swine
12. Number of animals: Approximately 3605
13. Length of confinement: Year Round
14. Are crops or pasture sustained in normal growing season over
any portion of the facility? Adjacent pastureland available
for land application, although acreage may not be adequate.
15. Types of waste management: containment buildings, solids
collectors, pipes and associated apertures and two lagoons.
16. Description of other animal operations in immediate vicinity:
None
17. Proximity of facility to neighboring houses, wells, etc.:
Unknown.

Inspection Form For Animal Operations
Page 2
18. Groundwater depth: Unknown
19. Proximity of facility to surface waters: From the pipe in
the new lagoon approximately 50 yards.
20. Was an Animal Waste Discharge occurring during the
inspection? Yes, please see attached photographs.
21. Are pollutants discharged into waters of the State?
Yes, please see attached photographs.
22. Was the subject discharge caused by a 25yr./24hr. storm
event: No.

J'-3a-399S 35 2b FROM DEM WATER QUALITY SECTION 70
FIFO. F - 02/02
I
Site Requires immediate A Ite mi on .
- Facility No.
DIVISION OF'ENVIRON ENTAL N ANAGEM ENT
ANIMAL FEEDLOT OPERATIONS SITE ViSr'ATION RECORD.
DATE: 1 1995
Time:
Farm Name/Own � 5,-
bAading Address:..,_,
Integrator Phone:
On Site Representative: _ Phone:.
Physical AddresslLocadon:
Type of Operation. Swine Poultry Cattle
Design Capacity: _ - Number- of Animals on Site:
DF-M Certification Number. ACE Dtz1�1 Ce d cation N=ber: ACNEW
Ladr de: Longitude: _ - _' Elevation: Feet
Circle Yes or No
Does [he Amirnal Waste Lagoon have sufficient freeboard of 1 Foot + 25 year 24 hour storm event
(approc%mately l Foot + 7 .inches) 0or No Actual Freeboard: -__—Fc. _ _ Luches
Was any seepage. observed from the lagoou(s)? Yes or 70:) Was any erosion observed? or No
Is adequate land available for spray? Yes No is the cover crop adequate? Yes or o
Cmp(s) being utilized.
Does the facWty meet SCS minimum setback criteria'? 200 Feer.from.Dwellings.?P, or Ko
100 Feet fmm Wells? or No
te anima waste stockpiled within 100 Feet of USGS Slue Une•Sttam7 e N ^'
animal waste land applied or shay irrigated within 25 Fect of a liSGS Map Blue Line'? �or No
7,, animal waste discharged into of the state by inan-rnadcditch, flushing system;, or other
�ir^ila_* man-made devices. Y,� i�r No Jt ]r�s, Please Explain.
' a+MG; rile facility maintain adequate waste mauagement records (volumes of nyanwe, land applied.
sTray inigared on specific acreage with cover crop)? Yes.,or No
Additional Comments: lap '� ` I �f1 tr �j(
*`
�• t.:;t:,: ignansre
cc: Faciliry Assessment Unitr: se Attachments if Needed
N�

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State of North Carolina
Department of Environment,
Health and Natural Resources •
Raleigh Regional Office
James B. Hunt, ,Secreta� � �
IL
Jonathan B. Howes, Secretary E C F1
Boyce A. Hudson, Regional Manager
RALEIGH REGIONAL OFFICE
September 7, 1995
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. C. B. Bunting
Route 1, Box 144B.
Pinetops, NC 27864
Subject: NOTICE OF VIOLATION
RECOMMENDATION FOR ENFORCEMENT
Swine Operation
SR 1505
Edgecombe County
Dear Mr. Bunting:
On August 15, 1995, Mr, Eric Fleek of the Raleigh Regional
Office conducted a re -inspection of the subject animal operation.
This inspection is a part of the Division's efforts to determine
potential problems associated with liquid waste disposal systems.
During the site visit, Mr. Fleek observed large quantities of
uncontained waste adjacent to your newly constructed lagoon. In
addition, this lagoon and all of the uncontained waste adjacent.to
it is (according to a recent U. S. Department of Agriculture Soil
Conservation Service map) located in an intermittent unnamed
tributary of Deep Creek. Furthermore, Mr. Fleek found a manmade
conveyance (pipe) behind your new lagoon's dike. It was also
observed that wastewater discharged from this pipe had reached Deep
Creek, which is considered surface waters of the State and are
classified as C-NSW.
The above mentioned discharge is a violation of North Carolina
General Statue 143-215.1 (a) and the presence of the pipe is a
violation of North Carolina General Statue 143-215 (e) which
respectively states:
143--215.1 (a) "No person shall do any of the following things
or carry out any of the following activities until or unless
such person shall have applied for and received from the
Commission a permit therefor and shall have complied with such
conditions, if any as are prescribed by such permit.
1. Make any outlets into the waters of the State;"
3800 Barrett Drive, Suite 101, Raleigh, North Carolina 27609 Telephone [phone] FAX [phone]
. An Equal Opportunity Affirmative Action Employer W% recycled/ 10% post -consumer paper

'f
C. B. Bunting
Notice of Violation
Page 2
143-215(e) "Except as required by federal law or regulations,
the Commission may not adopt effluent standards or limitations
applicable to animal and poultry feeding operations.
Notwithstanding the foregoing, where manmade pipes, ditches,
or other conveyances have been constructed for the purpose of
willfully discharging pollutants to the waters of the State,
the Secretary shall have the authority to assess fines and
penalties not to exceed five thousand dollars ($5000.00) for
the first offense. The definitions and provisions of 40 code
of Federal Regulations 122.23 (July 1, 1990 edition) shall
apply to this subsectiPn"
This Office is issuing you a Notice of Violation regarding
this matter. You are required to immediately eliminate the illegal
discharge, which is subject to civil penalties of up to $10,000 per
day, in accordance with North Carolina General Statute 143-215.6.
Additionally, you must remove the manmade conveyance (pipe).
Furthermore, this Office will recommend to the Director that
the subject animal facility lose its Deemed Permitted Status which
will require the immediate development of a certified waste
management plan. This office is also considering recommending an
Enforcement Action for the manmade conveyance and for the illegal
discharges to surface waters of the State. Both of these violations
may result in assessment of civil penalties.
It is requested that you respond in writing to this Notice of
Violation no later than September 21, 1995. You should specifically
explain how you eliminated the discharges, why the pipe is in the
lagoon berm, how long it has been in place, and the date you
removed it. In addition, you should include a description of your
current waste management practices (type of equipment, acreage
available to apply wastewater, cover crop, frequency of waste
application etc.).
Please carefully address each of the aforementioned issues in
your response. Thank you for your assistance with this matter and
if you have any questions, please contact Mr. Eric'Fleek or Ms.
Judy Garrett at [phone].
Sincerely,
Kenneth Schuster, P.E.
Regional Supervisor
CC: Edgecombe County Soil and Water Conservation District
Edgecombe County Health Department
Mr. Steve Bennett-N.C. Division of Soil and Water Conservation
RRO-File Copy
Central Office -Water Quality

This photo depicts the manmade conveyance emanating from the dike
of the new lagoon. The pipe's location (despite its partial
concealment by the level of the wastewater and burial in the
dike) is indicated by the positioning of the soil probe. This
pipe has discharged large quantities of particularly pungent
wastewater to this immediate area and to Deep Creek which is
approximately 50 yards away.
s
WAPr '0-M&I
7+.

This photo depicts the large quantities of uncontained wastewater
located adjacent to the new lagoon. This shot is taken from the
far end of the new lagoon's dike looking upstream along the
intermittent tributary of'Deep Creek. The containment houses are
to the right and the older lagoon is to the left. Please note
that this waste has collected along the natural contours of the
intermittent stream bed.

This photo depicts the newly constructed lagoon. As stated
previously, this lagoon is located in an intermittent unnamed
tributary of Deep Creek. The old lagoon_ (still containing
wastewater) is discernible in the left background of this
picture. (NOTE: The next picture is taken close to the position
of the cow in this photo.)
g

-1a-1S95
15:26 FROM -OEM WATER DUALITY SECTION TO
RPJD P . 02/02
-r .*r7010
Site Requires immediate Attendor!-
Facility No.
DIVISION OF'ENVIRONMENTAL MANAGEWNT
ANIMAL FEEDLOT OPERATION SITE VISITATION RECORD
DATE: 5 , I995
Time -!`--
Mailing Adder'=: � h 4 i. f L3 -{�( tt2 4 / N G ' 7 K !;A .
County:
Integrator. Phone:
On Site Representative: Phone:.
Physical Address/Location: Q 5.,
Type of Operation: Swine Poultry Cattle
Design Capacity_ Number of Animals on Site.
DEM Certification Number. ACE DIEM Cerdflcaton Number: ACNEW..
Latitude: Longitude: Elevation: _ Feet
Circle Yes or No
Does the Animal Waste Lagoon have sufficient. *eeboard of i Foot + 25 year 24 hour storrn event
(appro)dmately I Foot + 7 inches) 0or No Acmal Freeboard: �t. Inches
Was any seepage observed from the lagoon(s�Y s or To Was any erosion observed? or No
Is adequate land available for spray'.? Yes o No Is the cover crop adequate? Yes or o
Crop(s) being utilized:
Does the facility meet 5CS minimum setback criteria? 200 Feet.from.DweIlings? or No
IQO Feet -from Wells. or No
he anzrnaI waste stockpiled within Lw Feet of USGS Blue Lrne Stxeam. es' Nt�
aiz mal waste lased applied or spray irrigated -within 25 Feet of a USGS Map Blue Line'? or No 4
animal waste discharged intolyrx of the state by wan-naadeditch, flushing system, or other
iimi:a_- man-rnadt; devrices'. 1; ur No Iffes. Please Explain-
s ms tilt facility maintain adequate waste nxarragemcnt records (volumes of ruanare, land applied,.
spray irrigated on specific acreage with cover crop)? Yes or Noc 1 ,!
Addition C4tIIm2 1ts:' d U Cr 71
r ,�'�, r ci/fn 1 n _ i .n : P
0
cc: Facility Assessment Unit
�'aclj
Cl
I ��OiO
A � � Li 9 1 1 Q11 / -L,s r-
i gna cure
Gp se Attachments if Needed,
� �I?
TOTPL P . 02

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J'�L-14-1995 15.2s FROM DEM WATER LIUAL I TY SECTION TO
Site Requires Immediate A gten6jon-
Facility No.
DIVISION OF ENVIRONMENTAL MANAGEMENT
ANPviAL FEEDLOT OPEkA'11ONS SITE VISITATION RECORD
DATE: � ) , 1995
Time:
`�pp�
F:una Name/Owzler: , , < � ✓ rt C? I�-�`i
Mailing Address: �Y� rv�-
County -
Integrator: Phone:
On Site Representative: 3->�scC _ Phone: _ (oy j - 4'-? 2-(o �T
Physical Address/Location: _ h C� iU Gil N� F _ ^4M+ S,,4
Type of Operation: wine PvKery.• Poultry Cattle
Design Capacity: 2-0a 0D° r Number of Animals on Site: -S!
DEM Certification Number: ACE DEM Certification Number: ACNEW_
Latitude:" _ ya _" Longitude:" �� ' �3" Elevation: Feet
Fro... l` b Circle: Yes or No
Does the Animal Waste Lagoon have sufficientfreeboard or 1 Foot -t- 25 year 24 hour storm event
(approximately l Foot + 7 inches) Or No Actual Freeboard: 2 Ft. .inches
Was any seepage observed from the lagoons)? )t es No Was any erosion observed'? es r No
Is adequate land available for spray'.? Yes or .� o � „[s the crop adequate? Yes o No
Crop(s) being utilized. �+r`�- ---�- -- _ _ _ _ -- _
Doer the facility meet SCS minimum setback criteria) 200 Feet from DwelIings? es No
100 Feet from Wells? 6:5,�.br No
r a^irlal waste stockpiled within 100 Feet of USGS Piuc Line Stream? Yes or NO
a:limal waste land applied or spray irrigated within 25 Feet of a USGS Map Blue Line'? Yes o No
animal waste discharged into waters of the state by inan-made ditch, >zlushin>_ system, or uther
;iTr i'ar Mall -Made �iGti�iCeS'' :YG ,1 do li Y-,ts, please F <plaid.
;,c,; :tic: r:tcilit.v maintain adequate waste 111aila�31eT11CM TCC:tjFds (volumes of manilre, land applied.
spray irdgwed on specific acrc;age with cover crop.)'? 'Yes aONO
rkciditional Comments:
Y'L 4 �.x S
cc: Facility Assessment Unit Use Attachments if Needed.
o h
TOTAL P . 02'

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