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HomeMy WebLinkAbout820246_ENFORCEMENT_20171231NUH I H UAHULINA Department of Environmental Qua! Sampson Soil & Water Conservation District 84 County Complex Road Clinton, N.C. 28328 September 6, 2001 Mr. Bob Heath Division of Water Quality 225 Green Street Suite 714 Fayetteville, N.C. 28301 Dear W. Heath_ Phone: 592-7963 Ext, 3 DENR-FRO a. The Sampson Soil & Water Conservation District along with the Natural Resources Conservation Service is currently assisting Mr. Calvin Edwards with improvements to his swine waste management system at his request (facility number 82-246). We have determined that a majority of the lagoon volume is filled with sludge; therefore, adequate biological treatment of the waste is precluded. This explains the high nitrogen concentrations shown on many of Mr. Edwards' waste analysis reports. This high volume of sludge may have contributed to irrigation system problems such as clogged nozzles and skewed application amounts_ Mr. Edwards is planning to have the sludge removed from the lagoon, and we will assist in writing a sludge plan for its removal. We have also evaluated his existing irrigation system and have recommended that a new system be installed. Mr. Edwards has enrolled in the N.C. Agriculture Cost Share Program and will receive financial and technical assistance with this installation. Recent waste application records may not be very accurate due to current sprinkler spacing and skewed application amounts. Upon completing the aforementioned items, Mr. Edwards' waste management system should provide for the proper treatment and application of the waste and, therefore, future records should be more reliable. Sincerely, Danny Edwards Ag. Cost Share State of North Carolina Department of Environment and Natural Resources Michael F. Easley, Governor William G. Ross Jr., Secretary Kerr T. Stevens, Director June 4, 2001 CERTIFIED MAIL. RETURN RECEIPT REQUESTED Calvin Edwards Calvin Edwards Farm PO Box 472 Roseboro NC 28382 NO.W'd IT 0 0 A&4;1 2 NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND'NATURAL RESOURCES Subject: Notification for Wettable. Acre Determination Animal Waste Management System Calvin Edwards Farm Facility Number 82-246 Sampson County Dear Calvin Edwards: A letter dated January 15, 1999 was sent to advise you about concerns associated with Certified Animal Waste Management Plans and the method by which the irrigated acres within the plans were calculated. Only the acres that are wetted can be credited in the waste management plan as receiving waste application. Any acreage within the plan that can not be reached by waste application equipment can not be used as part of your plan. An evaluation by Trent Allen on 3/10/99 was made to review the actual number of acres at your facility that receive animal waste during land application. The evaluation of your facility has yielded one of the following two results as indicated by the box marked with an "X". Category 1: ❑ The evaluation of your facility could not be completed due to a lack of information. Please contact your Technical Specialist to assist in providing Trent Allen the necessary information to potentially exempt your facility from undergoing a complete wettable acre determination. Please submit this information to Trent Allen, at 225 Green Street, Suite 714, Fayetteville, NC 28301, within in 90 days of the receipt of this letter. If you have any questions please contact Trent Allen at (910) 486-1541. If within 90 days you are unable to provide Trent Allen with the information you are automatically required to complete a Wettable Acre Determination as described by Category 2 below, within 180 days of receipt of this letter. 16I7 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone 919-733-5083 Fax 919-715-6048 An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper Notification for Wettable Acre Determination Animal Waste Management System Page 2 Category 2: Your facility has been identified by the Department of Environment and Natural Resources as a facility that may have overestimated the number of acres actually receiving animal waste. Therefore, some or all of your fields may be exceeding the allowable loading rates set in your Certified Animal Waste Management Plan. In order to resolve this issue, please contact a designated Technical Specialist to have him or her conduct a Wettable Acre Determination for your facility. The Technical Specialist must be one that has been approved by the Soil and Water Conservation Commission to conduct Wettable Acre Determinations. Many Technical Specialist with the N.C. Cooperative Extension Service, the Soil and Water Conservation Districts, the Natural Resources Conservation Service, and the Division of Soil and Water Conservation have received this special designation. You may also contact a private Technical Specialist who has received this designation, or a Professional Engineer. All needed modifications to your Animal Waste Management System must be made and the Wettable Acres Determination Certification must be retumed to DWQ within the next 180 days. If the needed modifications are not made and if the form is not returned within the required time, DWQ will be forced to take appropriate enforcement actions to bring this facility into compliance. These actions may include civil penalty assessments, permit revocation, and/or injunctive relief. Once a Wettable Acre Determination has been completed, a copy of the attached Wettable Acre Determination Certification must be submitted to the address listed on the form. Please note that both the owner and the Technical Specialist must sign the certification. A copy of all the Wettable Acre Determination documentation that applies to your Waste Utilization Plan must be kept at your facility. DWQ and the Division of Soil & Water Conservation Staff will review all documentation during their annual visit of your facility. An additional copy must by kept on file at the local Soil & Water Conservation District Office. Please note that if you install or modify your irrigation system, a designated Irrigation Specialist or a Professional Engineer must also sign the Wettable Acre Determination Certification. Please be advised that nothing in this letter should be taken as removing from you the responsibility or Iiability for failure to comply with any State Rule, State Statute, Local County Ordinance, or permitting requirement. If you have any questions regarding this letter, please do not hesitate to contact Sonya Avant of our Central Office staff at (919) 733-5083 ext. 571. Sincerely, Kerr T. Stevens cc: Fayetteville Regional Office Sampson County Soil and Water Conservation District Facility File Murphy Family Farms MURPHY F A M I L T F A R M S May 3, 2001 Paul E. Rawls Regional Water Quality Supervisor Fayetteville Regional Office Division of Water Quality 225 Green Street Suite 714 Fayetteville, NC 28301-5043 Mr. Rawls, wr i i m DWQ I am writing on behalf of the Calvin Edwards Farm, Facility No. 82-246, in response to the NOV issued by your office on 4119101. The overapplications on setups 6,7,8,9,10,and 11, were unintentional and due to a mathematical error that Mr. Edwards made on his IRR -2's. I have contacted Dan Baily at the Sampson County Extension office and requested that he assist Mr. Edwards with record keeping. I have also redone his IRR -2's to reflect what has actually been irrigated. In setting up the IRR -2's for his upcoming Bermuda crop, I have subtracted what was overapplied on the small grain from the Bermuda crop. I have also contacted an Irrigation specialist to come out and calibrate the pressure at his sprinklers. Mr. Edwards has also been advised to take another lagoon sample. Mr. Edwards will make every effort to irrigate the effluent in compliance with all rules and regulations. Care will be taken in the future, as in the past, to prevent over spray. Mr. Calvin Edwards is an elderly farmer, who made an unfortunate, unintentional mistake, and I am requesting any leniency you may be able to provide. Enclosed are all of the requested documents. If there are any questions or concerns regarding this or the enclosed documents, please feel free to call me at (910) 289 2111. Sincerely, -J� Toni King Murphy Farms, Inc. Post Office Box 759, Rose Hill, North Carolina 28458, (910) 289-2111, FAX (910) 289-6400 North Carolina Department of Environment and Natural Resources Division of Water Quality � Fayetteville Regional Office RCDENR Michael F. Easley, Governor William G. Ross, Jr., Secretary Kerr T. Stevens, Director April 19, 2001 CERTIFIED MAIL RETURN RECEIPT RFS EJ STED Mr. Calvin Edwards P. O. Box 472 Roseboro, NC 28382 Subject: Notice of Violation/Notice of TutCnt Administrative Code 15A NCAC 211.0217 Calvin Edwards Faun Facility Nos. 82-246 Sampson County Dear Mr. Edwards: You are hereby notified that, having been Permitted to have a non discharge permit for the subject animal waste disposal system pursuant to 15A NCAC 2H.0217, you have been found to be in violation of your 211.0217 Permit_ On March 15, 2001, staff from the Fayetteville Regional Office of the Division of Soil and Water performed an annual review of the Calvin Edwards Farm in Sampson County. The review revealed that there was over application of nitrogen to the small grain crop as listed: setup #6 (40 lbs. over), setup #7 (25 lbs. over), setup #8 (39 lbs. over), setup #9, 410, and #11 (85 lbs. over). This is a violation of your CAWMP and the General Permit Condition 1H.6.f., which requires Regional notification of over application. This violation was referred to the Division of Water Quality, as required, by the Division of Soil and Water. The Division of Water Quality requests that the following item(s) be addressed: Avoid over application of nitrogen to any crop in your Certified Animal Waste Management Plan (CAWMP). 2. Over application shall be reported per the General Permit. 3. Submit freeboard records for the past twelve months. 4. Submit irrigation records for the past twelve months. 5. Submit a copy of the most recent CAWMP for your facility. 225 GREEN STREET — SUITE 7141 SYSTEL BUILDING / FAYETTEVILLE, NC 28301-5043 PHONE (910) 486-1541 FAX (910) 486-0707 WWW. T " ' AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER — 50% RECYCLED/I O°1a POST CONSUMER PAPER IJENR TOLL FREE HOTLINE: 1-877-623-6748 Mr. Edwards 4-11-01 Page 2 Failure to comply with the above conditions may result in the facility losing it's General Permit and being required to obtain an individual non discharge permit for the facility. Please be advised that this notice sloes not prevent the Division of Water Quality from taking enforcement actions for this violation or any past or future violation. You are hereby notified that based on the above information, the Division of Water Quality is considering forwarding recommendation to the Director for consideration of enforcement for this violation. Furthermore, the Division of Water Quality has the authority to levy a civil penalty of not more than $25,000.00 per day per violation. If you have an explanation for this violation that you wish to present to this office, please forward a detailed explanation, in writing, of the events noted and why you feel that this office should not proceed with recommendation for enforcement. This response should be received by this office on or before May 10, 20Q1. Information provided to this office will be reviewed and if enforcement is still deemed appropriate, your explanation will be forwarded to the Director with the enforcement package for his consideration. If you have any questions concerning this matter, please do not hesitate to contact either myself or Mr. John C. Hasty, Jr., Environmental Specialist, at (910) 486 -1541 - PER/ich cc: Sonya Avant - Compliance Group Wilson Spencer - Sampson Co. MRCS Trent Allen - DSWC Fayetteville Office Dennis Ramsey -Compliance Group Central Files - Raleigh John Bizic-Murphy Family Farms Sincerely, Paul E. Rawls Water Quality Regional Supervisor s . State of North Carolina Department of Environment and Natural Resources Fayetteville Regional Office Michael F. Easley, Governor William G: Ross, Secretary Division of Soil & Water Conservation Mr. Calvin Edwards P.O. Box 472 Roseboro, North Carolina 28382 MAR 2 3 2QDl March 23, 2001 SUBJECT: Operation Review Notice of Referral for Calvin Edwards Farm, Facility Number 82-246 Sampson County Dear Mr. Edwards, ZEMAJ P�� NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RE50URCEs z3v- On March 15, 2001, an operation review was conducted of Calvin Edwards Farm, facility number 82-246, in Sampson County. This review, undertaken in accordance with G.S. 143- 215.10D, is one of two routine site visits scheduled for all subject animal operations in 2001. Staff from the Division of Water Quality will conduct a separate compliance inspection. During the operation review, the following items were noted: • Over application to the small grain crop. Setups 6-11 were over applied on at rates from 25 pounds of nitrogen up to 85 pounds of nitrogen. The over applied amounts were greater than 10% allowed by the waste plan and require a notice of referral to the Division of Water Quality. It was for these reasons that your operation was referred to the Division of Water Quality for further investigation and possible enforcement action. G.S. 143-215.10E requires staff from the Division of Soil and Water Conservation to notify the Division of Water Quality and the owner/operator of these observed violations. 225 Green Street, Suite 7141 Systel Bld. Fayetteville, North Carolina 28301-5043 Telephone 910-486-1541 FAX 910-486-0707 An Equal Opportunity Affirmative Action Employer A s t Mr. Calvin Edwards March 23, 2001 Page 2 A copy of the operation review report is enclosed for your information. Site findings and recommended corrective actions as discussed are noted in the comment sections. Please remember that in order for your facility to remain in compliance with environmental regulations, animal waste cannot be discharged into the waters of the State, and the animal waste collection, treatment, storage and disposal systems must be properly maintained and operated under the responsible charge of a certified operator. On behalf of the Division of Soil and Water Conservation, I appreciate your cooperation with this operation review. Please do not hesitate to contact me at 910-486-1541 if you have any questions, concerns or need additional information. Sincerely, Trent Allen Environmental Engineer CC' Paul Rawls, Division of Water Quality Wilson Spencer, Sampson Soil & Water Conservation District Kraig Westerbeek, Murphy Farms Carroll Pierce, Division of Soil & Water Conservation 225 Green Street, Suite 7141 Systel Sld. Fayetteville, North Carolina 28301-5043 Telephone 910486-1541 FAX 910-486-0707 An Equal opportunity Affirmative Action Employer 0,Division of Soil and Water Conservation,i,,,, ; 0 Other Agencyr " Type of Visit O Compliance Inspection O Operation Review O Lagoon Evaluation Reason for Visit O Routine O Complaint O Follow up O Emergency Notification O Other ❑ Denied Access Facility Number 82 246 Dale of Visit: 3-15 200] 't•irne: ]0:20 10 Not Operational O Below Threshold ® Permitted M Certified [3 Conditionally Certified 13 Registered Date Last Operated or Above Threshold:............ Farm Name: �lxin..>athf_aK�A�. atrnn............................................................................... County: S&M5wn................ Owner Name:.alyip..................................... EIII.Y.ArdS........................... Phone No: Mailing Address: JPQ.B.ox..4.7.1...... Facility Contact::;��Y.'At1..t�!i'.af............. .................................. I ...... ... ............ R!?Se.12Qro-NK........... I ............... JFRO ....... I......... Z83.871. .................Title:............................................................... Phone No:............................ . Onsite Representative: CAJ.yitn._dtrarsis ........................ ............ Integrator: MQrpbx.,F.arWl.):.FAA=........... Certified Operator: C.al.Y.its.................................... Ed.wards........................................... Operator Certification Number: 2.0.01.9.. Location of Farm: ,rom Garland, take NC 411 toward Roseboro, go 0.7 mile past intersection of NC 411 and NC 242 just outside of Roseboro + Ind turn left onto SR 1246, go about 1.0 mile then turn right onto SR 1254 (Microwave Tower Road), go 1.3 miles to farm ® Swine ❑ Poultry ❑ Cattle ❑ Horse Latitude 34 ' S7 20 Longitude 78 a 32 30 Design Current Swine Canacitv Ponulation ® Wean to Feeder 2600 ❑ Feeder to Finish ❑ Farrow to Wean ❑ Farrow to Feeder ❑ Farrow to Finish ❑ Gilts ❑ Boars Design Current Design Current Poultry Capacity Population Cattle Capacity Population ❑ Layer EE] Dairy ❑ Non -Layer ❑ Non -Dairy ❑ Other Total Design Capacity 2,600 Total SSLW 78,000 Number of Lagoons I ❑ Subsurface Drains Present ❑ Lagoon Area 10 Spray Field Area Holding Ponds / Solid Traps ❑ No Liquid Waste Management System Discharees & Stream Imnacts 1. Is any discharge observed from any part of the operation? ❑ Yes M No Discharge originated at: ❑ Lagoon ❑ Spray Field ❑ Other a. if discharge is observed, was the conveyance man-made? ❑ Yes M No b. If discharge is observed, did it reach Water of the State? (If yes, notify DWQ) El Yes ®No c. If discharge is observed, what is the estimated flo„, in gal/min? nla d. Does discharge bypass a lagoon system? (If yes, notify DWQ) ❑ Yes M No 2. Is there evidence of past discharge from any part of the operation? ❑ Yes M No 3. Were there any adverse impacts or potential adverse impacts to the Waters of the State other than from a discharge? ❑ Yes M No 01/01/01 Continued F xiUty' umber: 82-246 hate of Inspection 3 -IS -2001 Waste Collection & Treatment 4. Is storage capacity (Freeboard plus storm storage) less than adequate? ❑ Spillway ❑ Yes N No Structure 1 Structure 2 Structure 3 Structure 4 Structure 5 Structure 6 Identifier: ....................................................................................................................................................................................................................... Freeboard(inches) ............... .3 ............... ................................... .................................... ................................... ...................................................................... 5. Are there any immediate threats to the integrity of any of the structures observed? (ie/ trees, severe erosion, ❑ Yes N No seepage, etc.) 6. Are there structures on-site which are not properly addressed and/or managed through a waste management or closure plan? El Yes ®No (If any of questions 4-6 was answered yes, and the situation poses an immediate public health or environmental threat, notify DWQ) 7. Do any of the structures need maintenance/improvement? ❑ Yes N No 8. Does any part of the waste management system other than waste structures require maintenance/improvement? ❑ Yes ® No 9. Do any stuctures lack adequate, gauged markers with required maximum and minimum liquid level elevation markings? [-]Yes ® No Waste Application 10. Are there any buffers that need maintenance/improvement? ❑ Yes N No 11. Is there evidence of over application? ❑ Excessive Ponding ® PAN ❑ Hydraulic Overload ® Yes ❑ No 12. Crop type Coastal Bermuda (Hay) Small Grain Overseed 13. Do the receiving crops differ with those designated in the Certified Animal Waste Management Plan (CAWMP)'? ❑ Yes N No 14. a) Does the facility lack adequate acreage for land application? ❑ Yes ❑ No b) Does the facility need a wettable acre determination? ❑ Yes ❑ No c) This facility is pended for a wettable acre determination? ❑ Yes ❑ No 15. Does the receiving crop need improvement? ❑ Yes ® No 16. is there a lack of adequate waste application equipment? ❑ Yes ® No 17. Are rock outcrops present? ❑ Yes ❑ No I S. Is there a water supply well within 250 feet of the sprayfield boundary? ❑ Unknown ❑ Yes ❑ No ❑ On-site [-] Off-site Required Records &Documents 19. Fail to have Certificate of Coverage & General Permit or other Permit readily available? ❑ Yes ® No 20. Does the facility fail to have all components of the Certified Animal Waste Management Plan readily available? (ie/ WUP, checklists, design, maps, etc.) ❑ Yes N No 21. Does record keeping need improvement? (ie/ irrigation, freeboard, waste analysis & soil sample reports) ® Yes ❑ No 22. 1s facility not in compliance with any applicable setback criteria in effect at the time of design? ❑ Yes ® No 23. Did the facility fail to have a actively certified operator in charge? ❑ Yes ®No 24. Fail to notify regional DWQ of emergency situations as required by General Permit? (ie/ discharge, freeboard problems, over application) ❑ Yes N No 25. Did Reviewer/Inspector fail to discuss review/inspection with on-site representative? ❑ Yes ® No 26. Does facility require a follow-up visit by same agency? ❑ Yes ® No 27. Were any additional problems noted which cause noncompliance of the Certified AWMP? ❑ Yes N No Odor Issues 28. Does the discharge pipe from the confinement building to the storage pond or lagoon fail to discharge at/or below ❑ Yes ❑ No liquid level of lagoon or storage pond with no agitation? 29. Are there any dead animals not disposed of properly within 24 hours? ❑ Yes ® No 01/01/01 Continued 14'Qity Number: 82-246 Date of Inspection 3-15-2001 30. Is there any evidence of wind drift during land application? (i.e. residue on neighboring vegetation, asphalt, roads, building structure, and/or public property) 31. Is the land application spray system intake not located near the liquid surface of the lagoon? 32. Were any major maintenance problems with the ventilation fan(s) noted? (i.e. broken fan belts, missing or or broken fan blade(s), inoperable shutters, etc.) 33. Do the animals feed storage bins fail to have appropriate cover? 34. Do the flush tanks lack a submerged fill pipe or a permanent/temporary cover? Printed on: 3/23/2001 ❑ Yes ® No ❑ Yes ® No ❑ Yes ® No ❑ Yes ® No ❑ Yes ❑ No Q No violations or deficiencies were noted during this visit. You will receive no further correspondence about this visit. Comments (refer to question ##): Explain any YES answers and/or any recommendations or any other comments. Use drawings of facility tobetter explain situations.. (use additional, pages as necessary): El Field Copy ❑Final Notes ' I I- There was over application on the small grain. + Setup #6 was at 90 lbs. of nitrogen - 40 lbs. over Setup #7 was at 75 lbs. of nitrogen - 25 lbs. over Setup #8 was at 89 lbs. of nitrogen - 39 lbs. over Setup 49, #10, and #11 were at 135 lbs. of nitrogen - 85 lbs. over he 8-14-2000 waste sample was used to calculate the winter pumping totals. Sample was 1.8 lbs./1000 gals. 21- Make sure to keep waste samples updated. Samples are good for 60 days before and after sample date. Notice of referral will be sent to DWQ. Reviewer/Inspector Dame Trent Allen Reviewer/Inspector Signature: Date: 01/01/01 I= 02V NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES FAYETTEVILLE REGIONAL OFFICE DIVISION OF WATER QUALITY September 24, 1998 CERTIFIED MAEL RETURN RECEIPT REQUESTED Mr. Calvin Edwards P.O. Box 472 Roseboro, NC 28382 SUBJECT: NOTICE OF DEFICIENCY Calvin Edwards Swine Facility Registration No. 82-246 Sampson County Dear Mr. Edwards: On September 21, 1998, staff from the Fayetteville Regional Office of the Division of Water Quality inspected the Edwards swine facility. It was observed that an overapplication of nitrogen had been applied on the rye crop during the 97-98 winter season. It was also observed that the bermuda grass waste application field had a poor to non-existent stand in one area of the spray field. In regard to the deficiencies noted during the inspection, the following actions are requested: 1. Consult with a technical specialist for assistance in regard to the establishment of the bermuda grass in waste application field. 2. Contact a technical specialist for assistance with possible modifications to the CAWMP to assist in preventing an overapplication frown occurring in the future. 17 Please notify this office on or before October 20 1998 at the address ti below as to the actions taken or proposed to be taken to resolve this deficiency. Nothing in this letter should be taken as absolving this facility of the responsibility and liability of any violations that have or may result from these deficiencies. 225 GREEN STREET, SUITE 714, FAYETTEVILLE, NORTH CAROLINA 28301-5049 PHONE 910-466-1541 FAX 910-486-0707 AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/i 0% POST -CONSUMER PAPER Mr. Edwards Page 2 September 24, 1998 If you have any questions concerning this matter, please call Bob Heath, at (910) 486-1541. Sincerely, Robert F. Heath Environmental Specialist cc: Operations Branch Central Files Audrey Oxendine - FRO DSW Wilson Spencer - Sampson Co. MRCS State of North Carolina Department of Environment, Health and Natural Resources A00 -4f) Fayetteville Regional OfficeOn% ,lames B. Hunt, Jr., Governor p E H N FR Jonathan B. Howes, Secretary DIVISION OF WATER QUALITY October 13, 1997 CERTIFIED MAIL RETURN RECEIPI REQUESICED Mr. Calvin Edwards P..O. Box 472 Roseboro, NC 28382 SUBJECT: NOTICE OF DEFICIENCY Calvin Edwards Farre Registration No. 82-245 Sampson County Dear M. Edwards On October 9, 1997, staff from the Fayetteville Regional Office of the Division of Water Quality inspected the Calvin Edwards swine facility. It was observed that the facility did not have a copy of the certified animal waste management plan (CAWMP) on-site at the time of the inspection. The certified operator (Mr. Edwards) needs to maintain pump records by zone on the IRR -1 form and calculate the plant available nitrogen (PAN) balance on the M-2 form after all zones of the spray field have received waste equally. The bermuda grass has competition with other grasses and needs improving. In regard to the deficiencies noted during the inspection, the following actions are requested: 1. Consult with a technical specialist (MRCS) for assistance in regard to receiving a copy of the CAWMP. Submit a copy of the CAWMP to the Division of Water Quality with all certification forms for review to the Regional Office at the address on the bottom of the letterhead page. 2. Begin immediately maintaining records of all waste application on the IRR -1 form by zone and keep the PAN balance for the field on the IRR -2 form. 3. Consult with a technical specialist in regard to removing the undesirable grasses and weeds in the spray field to allow the bermuda grass to flourish. Please notify this office on or before November 12, 1997 at the address below as to the actions taken or proposed to be taken to resolve this deficiency. Nothing in this letter should be taken as absolving this facility of the responsibility and liability of any violations that have or may Wachovia Building, Suite 714, Fayetteville FAX 910-486-0707 North Carolina 28301-5043 C An Equal Opportunity Affirmative Action Employer Voice 910-486-1541 50% recycled/10% post -consumer paper Page 2 Mr. Calvin Edwards October 13, 1997 result from these deficiencies. If you have any questions concerning this matter, please call Bob Heath, at (910) 486-1541. Sincerely, Robert F. Heath Environmental Specialist cc: Operations Bra ch Central Files Audrey Oxendine - FRO DSW Wilson Spencer - Sampson Co. MRCS