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May 8, 1999
Mr. Grady Dobson
NC Dept. of Environment and Natural Resources
225 Green Street, Suite 714
Fayetteville, NC 28301
Re: Non -Compliance WQ0000672 City of Lumberton
Mr. Dobson:
m v 1 v 1999
F�"" r r t h._.' a C 3 4
REGj OFFnC—L-
I spoke with Kitty Cramer of your office on Friday, May 7, 1999, via telephone and informed her- of a
non-compliance in Lumberton which involved SOUR testing. The non-compliance occurred during the first
quarter,of 1999. The temperature in the digester was not within guidance, and was below` 10 degrees Celsius
When I initially calculated the SOUR test in January, I inadvertently overlooked the temperature guidance
requirement. On May 6, 1999,the Lab Supervisor and I were reviewing SOUR guidance regulations and the
January testing and that is when I noticed the non-compliance. I saw that the temperature in the digester.was
below the 10 degrees Celsius requirement; therefore, the data for the January SOUR test does not meeting the
Vector Reduction Requirement.
The amount of sludge hauled to receiver sites based on the inaccurate January SOUR data was 3,965,000
gallons. The following actions will be taken to ensure that this oversight of interpreting data does not recur:
1. No SOUR testing will be done when digester temperature is below 10 degrees Celsius.
2. I will carefully evaluate SOUR data prior to qualifying compliance per 503 Sludge Guidance documents.
3. Laboratorypersonnel performing Pathogen and Vector Reduction Tests (SOUW) will -be instructed per --
Standard Methods for the Examination of Water and Wastewater and EPA.Guidance documents.
It is the goal and intention of the Lumberton Wastewater Treatment Plant personnel to meet, and exceed .
when possible, all federal and state guidelines concerning the handling of sludge. Precautions will be taken to
avoid future non-compliance. If any additional information is needed, please do not hesitate to contact me.
Sincerely,
Howard Revels, Chief Operator
cc: W. Todd Powell, City Manager
H. Dixon Ivey, Public Works/Utilities Director
Rob Willcox; S&ME, Inc.
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May 6, 1999
Mr. Kevin Barnett '
Non -Discharge Compliance Enforcement Unit
NCDENR
P. O. Box 29535
Raleigh, NC 27626-0535
Subject: Response to Notice of Violation
1998 Annual Biosolids Report
Permit No. WQ 0000672
City of Lumberton
Dear Mr. Barnett:
J U L 2 6 1999
FAYETTEVILLE
RIEG. OFFICE
The City of Lumberton received a Notice of Violation for fourth quartef'Specific Oxygen Uptake (SOUR)
test results. The (SOUR) test results were performed on percent (%) solids greater than 2%. The facility
performed (SOUR) testing October 12'h through October 215L, 1998 with a 2.21% solids. The North
Carolina Department of Environment and Natural Resources mailed guidance on (SOUR) testing, dated
November 17. 1998.
The fourth quarter (SOUR) testing was completed prior to receiving guidance. The facility could not.
perform a second (SOUR) testing due to solids concentration in all digesters above 3.5% The fourth
quarter (SOUR) violation was not due to a willful disrespect of not complying with guidance. ,
The follow is our corrective action plan:
(1) To perform future (SOUR) test, based on percent (%) solids less than 2%.
(2) Evaluate and review existing (SOUR) test procedures and investigate alternative Vector
Attraction methods.
(3) Strive to be in compliance by doing our best.
Sincerely,-
"(
Howard Revels
W WTP Chief Operator
HR/sh
cc: Todd Powell, City Manager
H. Dixon Ivey, Public Works/Utilities Director
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POST OFFICE BOX 1388
LUMBERTON, N.C. 28359-1388
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Mr. Grady Dobson
NC Dept. of Environment and Natural' Resources
225 Green Street, Suite 714
Fayetteville, NC 28301
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