WQ0003698_Compliance Evaluation Inspection_20211206

SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED

December 6, 2021

Brant Sikes
Email: [e-mail]
City of Marion

SUBJECT: Compliance Inspection Report
Corpening Creek WWTP-Inactive Sludge Disposal Site
Non-discharge Permit No. WQ0003698
McDowell County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Corpening Creek WWTP Inactive
Sludge Disposal Site on 11/05/2021. This inspection was initiated based on the discovery of a sludge pit not
listed in the current permit. The findings and comments noted during this inspection are provided in the
enclosed copy of the inspection report. Please note, the facility is currently non-compliant with the
requirements of the permit based on continued groundwater exceedances. The exceedances and required
corrective action will be addressed under separate cover.

If you should have any questions, please do not hesitate to contact Brett Laverty at 828-296-
4681/[e-mail] or me at 828-296-4686/[e-mail].

Sincerely,

Mikal Willmer, Environmental Specialist II
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report

Ec: LF
Bob Boyette, City Manager
DocuSign Envelope ID: 9B3B0089-6B81-40FD-ABC5-01F2485386E9
Compliance Inspection Report
Permit:WQ0003698 Effective:08/01/17 Expiration:07/31/22 Owner :City of Marion
SOC:
Contact Person:
Region:
County:
Directions to Facility:
McDowell
Asheville
Brant Sikes
Effective:Expiration:Facility:Corpening Creek WWTP
3982 NC Hwy 226 S
Marion NC 28752
Title:Phone:[phone]
From ARO: Take I-40 east to Exit 86 in Marion. Turn left onto Hwy. 226. Turn right onto College Drive (SR 1819), Disposal Unit is
located approximately 1/2 mile on left after crossing RR tracks.
Secondary ORC(s):
Phone:Certification:Primary ORC:
System Classifications:
On-Site Representative(s):
Related Permits:
NC0031879 City of Marion - Corpening Creek WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
11/05/2021 12:00PM 03:00PM
Mikal Willmer 828-296-4686
Brett Laverty
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Other
Surface Disposal of Residual Solids (503)
Compliance Evaluation
Question Areas:
Miscellaneous Questions Record Keeping Sampling
Wells
(See attachment summary)
Page 1 of 3
DocuSign Envelope ID: 9B3B0089-6B81-40FD-ABC5-01F2485386E9
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0003698
11/05/2021 Compliance Evaluation
City of Marion
Other
Inspection Summary:
Mikal Willmer and Brett Laverty, of the Asheville regional office, conducted a compliance evaluation inspection in conjunction
with a site evaluation of the inactive Marion Surface Disposal Unit (WQ0003698) on November 5, 2021. This site visit was
initiated based on the discovery of a surface disposal pit not included in the current post-closure permit. Brant Sikes was
present and assisted in the inspection.
Below are the ARO’s recommendations, as pertains the current pits, and findings regarding the newly discovered residuals.
The City of Marion has updated their operation and maintenance plan for the site, which the Regional Office reviewed and
approved. The current documented pits appear to be maintained and the low-flow ground water monitoring is now being
conducted by Pace Analytical. The low flow sampling results indicate the City continues to exceed State groundwater
standards for Fe, Mn and NO3 at MW3, NH3, Fe and Mn at MW-2 and Fe and Mn at MW-4.
It was noted during the site visit that the pits are beginning to settle as the biosolids continue to decompose. Inspectors
recommended regrading and sowing the depressed areas to promote positive drainage. This is part of continual
maintenance until the residuals completely decompose or are properly excavated.
New Pits: It has been previously conveyed to the City that the extent of the sludge pits is unknown and that the field work
conducted by the Asheville regional office in 2009/2010 was not intended to replace a full site assessment by the City. The
ARO and Non-Discharge Permitting Staff recommended in February of 2021 that the site be fully assessed before any
development occurred onsite. The City notified our office on 10/22/2021 that DOT contractors began site work, earlier than
anticipated, and encountered biosolids while clearing and grading the site for the installation of an access road. The City
has chosen to excavate the biosolids and dispose of in a permitted landfill. Mr. Laverty provided Mr. Sikes with the
Division’s closure guidelines and required testing. This testing may vary from those required by the receiving landfill.
Subsoils analyses will determine whether further remediation is warranted after the biosolids are removed. Staff from the
ARO encountered additional biosolids and identified several other areas of interest based on LIDAR imagery. Please
reference Mr. Laverty’s email dated November 9, 2021, for a summary of site work conducted on November 5.

More extensive corrective actions will be addressed under separate cover. A Notice of Violation will be issued for the
continued groundwater violations and will include requirements and proposed timelines for implementing corrective actions
onsite. The ARO will also outline the requirements for a full site assessment to determine the extent of the sludge pits at
the site originally permitted by the Division in 1982 under Permit # 7013R.
Page 2 of 3
DocuSign Envelope ID: 9B3B0089-6B81-40FD-ABC5-01F2485386E9
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0003698
11/05/2021 Compliance Evaluation
City of Marion
Other
Type Yes No NA NE
Distribution and Marketing
Land Application
Record Keeping Yes No NA NE
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on-site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
This is a post-closure care permit. City continues to exceed groundwater standards at MW-2,
3 & 4. See summary for details. Any groundwater violations will be addressed under separate
cover.
Comment:
Sampling Yes No NA NE
Describe sampling:
Low-flow ground water monitoring required.
Is sampling adequate?
Is sampling representative?
sampling technique now appears to be providing representative data. Monitoring network may
need to be expanded. See summary for inspection details.
Comment:
Page 3 of 3
DocuSign Envelope ID: 9B3B0089-6B81-40FD-ABC5-01F2485386E9