WQ0002127_CEIARR 2023_20240618

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

June 18, 2024

Eli Self
City of Morganton
Email: [e-mail]

SUBJECT: Compliance Inspection Report
Annual Report Review 2023
City of Morganton Class A Residuals Program
Non-discharge Permit No. WQ0002127
Burke County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the City of Morganton Class
A Residuals Program on 6/18/2024. This inspection was conducted to verify that the facility is operating
in compliance with the conditions and limitations specified in Non-discharge Permit No. WQ0002127. The
findings and comments noted during this inspection are provided in the enclosed copy of the inspection
report entitled "Compliance Inspection Report".

There were no significant issues or findings noted during the inspection and therefore, a response to this
inspection report is not required.

If you should have any questions, please do not hesitate to contact Melanie Kemp with the Water
Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500 or via email at
[e-mail].

Sincerely,

Melanie Kemp, Environmental Specialist
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Compliance Evaluation Inspection Report

Ec: LF
Compliance Inspection Report
Permit:WQ0002127 Effective:03/01/23 Expiration:03/31/29 Owner :City of Morganton
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Burke
Asheville
Eli Self
Effective:Expiration:Facility:City of Morganton Class A Residuals Program
1000 Vine Arden Rd
Morganton NC 28655
Title:Phone:[phone]ORC
I-40 to Exit 105 to Hwy. 18N. Turn rt. on Hwy. 70 By-Pass, turn left @ light to Hwy. 70 W. Turn right on Kirksey Dr. Go approx. 1.25
miles to Vine Arden Road on right.
Secondary ORC(s):
828-438-5376Phone:[phone]Certification:Elisha J SelfPrimary ORC:
System Classifications:
On-Site Representative(s):
Related Permits:
NC0026573 City of Morganton - Catawba River Pollution Control Facility
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
06/18/2024 11:00AM 02:00PM
Melanie Kemp
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Distribution of Residual Solids (503)
Annual Report Review
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Pathogen and Vector Attraction
(See attachment summary)
Page 1 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0002127
06/18/2024 Annual Report Review
City of Morganton
Routine
Inspection Summary:
Melanie Kemp, with the Asheville Regional Office, conducted a review of the City of Morganton’s 2023 DCAR Annual Report
to determine whether the facility processed and monitored all residuals in compliance with non-discharge permit
WQ0002127.
The City produced approximately 1,084 metric dry tons and distributed approximately 580 metric dry tons of Class A
Compost to local businesses and individuals in 2023. All customers were provided with a utilization agreement listing the
requirements for proper use of the residuals.
Pathogen Reduction (PR): PR is met via fecal coliform density reduction below 1,000 MPN/g and through PFRP (Option E)
composting. The statically aerated piles appeared to exceed 55°C for at least three consecutive days. One of the 10/4/23
sampling values (<2.9) reported on form RSSF – B did not match the attached lab report but was still below regulatory limits
(<2.4).
Vector Attraction Reduction (VAR): VAR is met via the 14-day aerobic process (Option 5). All constructed piles appeared to
exceed 40°C for at least 14 consecutive days and had an average temperature that exceeded 45°C.
Non-Hazardous Waste Characterization: TCLP sampling is required once per permit cycle and needs to be completed
before 2029.
Metals, Nutrients & Pollutants of Concern: Reported values were below the monthly and ceiling concentration limits for
Class A products. Nutrients and metals were sampled quarterly. Note that October sampling results for Aluminum, Calcium,
pH, Potassium, Sodium, and Magnesium were provided in the attached lab reports but not reported on form RSSF.

PAN & SAR: PAN and SAR values appeared to be calculated correctly based on the attached paperwork. Please note that
4th quarter values were not provided, despite having the laboratory results to do so. The 4th quarter calculations were as
follows: PAN – 3,010; SAR – 0.85. Please be sure to provide the calculated PAN and SAR values on the RSSF form moving
forward. All SAR values for 2023 were below 10.
Page 2 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0002127
06/18/2024 Annual Report Review
City of Morganton
Routine
Type Yes No NA NE
Land Application
Distribution and Marketing
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?
Class A product (compost) is supplied to various customers. Hazardous waste characterization
is required once per permit cycle (before 2029). A few analyses provided in lab reports were
not reported on form RSSF - B (see summary). SAR and PAN values were properly calculated,
but should be reported on form RSSF. See summary for more details.
Comment:
Pathogen and Vector Attraction Yes No NA NE
a. Fecal coliform SM 9221 E (Class A or B)
Class A, all test must be <1000 MPN/dry gram
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
Fecal coliform SM 9222 D (Class B only)
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
b. pH records for alkaline stabilization (Class A)
c. pH records for alkaline stabilization (Class B)
Page 3 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0002127
06/18/2024 Annual Report Review
City of Morganton
Routine
Temperature corrected
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench-top Aerobic/Anaerobic digestion results
PFRP Option E (composting) is utilized. See summary for details.Comment:
Treatment Yes No NA NE
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
VAR Option 5 is utilized. See summary for details.Comment:
Page 4 of 4
Annual Report Review Class A Distribution Permit No. WQ00_________

Reporting Period: ___________

Permit Details:

• Is 503 OR 257
• Maximum Dry Tons Per Year: ________
• Monitoring Frequency for TCLP: ________
• Monitoring Frequency for Residuals Analysis: ________
• Monitoring Frequency for Pathogen & Vector Attraction Reduction: ________

1. Class A Annual Distribution and Marketing/Surface Disposal Certification Form
• Was a certification form submitted? Yes No
• Was distribution conducted during the reported period? Yes No
• How many dry tons were produced and distributed? ________
• Were the distributions with the permitted amount? ________
• Were recipient’s information listed? ________
• Did it indicate compliance? Yes No
• Was form complete? Yes No
• Was it signed by the appropriate people? Yes No

2. Monitoring
• Were the analyses conducted at the required frequency? Yes No
• Was an analyses taken for each source that was distributed? Yes No
• Were the metals analyses reported on the Residual Sampling Summary Form? Yes No
• Were the results reported in mg/kg? Yes No
• Were the pH’s 6.0 or greater for each residual sample? Yes No
• Were the heavy metals within ceiling concentration permit limits? Yes No
o Were the lab analyses attached? Yes No
• Were all the required parameters tested? Yes No
• Was TCLP analysis conducted? Yes No
• Were the TLCP contaminants within regulatory limits? Yes No
• Was a corrosivity, ignitability, and reactivity analysis conducted? Yes No

02127
2023
3,250
Once per permit cycle
None
Quarterly
Yes
Yes
Produced 1,084, distributed 580
Comments: TCLP required once per permit cycle, before 2029.Lab results for SAR and PAN were included in lab reports but not reported on form RSSF.PAN and SAR calculations for 4th Quarter are missing from the calcuation table but are as follows: PAN: 3,010 mg/kg; SAR: 0.85-The 4th quarter sampling results for the following were included in lab reports but not providedon form RSSF: aluminum, calcium, pH, potassium, sodium, and magnesium.
3. Pathogen and Vector Attraction Reduction
• Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted? Yes No
• Did the form indicate the period of coverage, the residual class, and the pathogen reduction alternative
and the vector attraction reduction option used? Yes No
• Was the appropriate documentation to show pathogen and vector attraction reduction included in the
report? Yes No
• Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503?Yes No

Class A Pathogen Review

To be Class A, residuals shall meet either fecal Coliform density or salmonella density.

Fecal Coliform density
· Was the sampling conducted at the required frequency? Yes No
· Were multiple samples taken? Yes No
· Was each sample less than 1000 MPN/gram of total solids? Yes No

OR

Salmonella density
· Was the sampling conducted at the required frequency? Yes No
· Were multiple samples taken? Yes No
· Was each sample less than 3 MPN/4 grams of total solids? Yes No

To be Class A, residuals shall meet one of the following alternatives:

Alternative 1 – Time/Temperature
· Were the residuals maintained for correct time and temperature? Yes No
· Were logs submitted showing time and temperature? Yes No
· Were temperatures within range for complete time period? Yes No

Alternative 2 – Alkaline Treatment
· Were logs submitted showing time and temperature? Yes No
· Was the pH raised to 12 or greater and maintained for 72 hours or longer? Yes No
· Was the temperature 52°C (126°F) for 12 hours or longer while the pH was 12 or greater?
Yes No
· Were logs submitted showing time and pH? Yes No
· Was the temperature corrected to 25°C (77°F)? Yes No

Alternative 5 – Process To Further Reduce Pathogens
PFRP Composting
· Were the within-vessel method or static aerated pile methods used? Yes No
· Was the residuals temperature maintained at 55°C (131°F) or higher for three consecutive days or
longer in the within-vessel method or static aerated pile method? Yes No
OR
· Was the windrow composting method used? Yes No
· Was the residuals temperature maintained at 55°C or higher for 15 consecutive days or longer in the
windrow method, and the windrow turned a minimum of five times during this time? Yes No
PFRP Heat Drying
· Was the residuals dried by direct or indirect contact with hot gases and the moisture content of
residuals reduced to 10% or lower? Yes No
· Did the temperature of the residuals or the of the wet bulb temperature of the gas in contact with the
residuals as the residuals leave the dryer exceed 80°C (176°F)? Yes No

Vector Attraction Reduction Review

• Was the sampling conducted at the required frequency? Yes No

Option 1 – 38% Volatile Solids Reduction
· Was there 38% reduction? Yes No
· Were lab sheets/calculations in report? Yes No
· Was the reduction on volatile solids (not total solids)? Yes No
· Were the samples taken at beginning of digestion process and before application (Inspection)?
Yes No
· Were calculations correct? Yes No

Option 2 – 40-Day Bench Scale Test
· Were residuals from anaerobically digested treatment (Inspection)? Yes No
· Were residuals anaerobically digested in lab? Yes No
· Was the test run for 40 days? Yes No
· Was the test done between 30°C (86°F) and 37°C (99°F)? Yes No
· Was the reduction of on volatile solids (not total solids)? Yes No
· Was the reduction less than 17%? Yes No
· Were lab sheets/calculations in report? Yes No
· Were calculations correct? Yes No

Option 3 – 30-Day Bench Scale Test
· Were residuals from aerobically digested treatment (Inspection)? Yes No
· Were residuals aerobically digested in lab? Yes No
· Were residuals 2% or less total solids? Yes No
· If not 2% total solids, was the test ran on a sample diluted to 2% with unchlorinated effluent?
Yes No
· Was the test run for 30 days? Yes No
· Was the test done at 20°C (68°F)? Yes No
· Was the reduction of on volatile solids (not total solids)? Yes No
· Was the reduction less than 15%? Yes No
· Were lab sheets/calculations in report? Yes No
· Were calculations correct? Yes No

Option 4 – Specific Oxygen Uptake Rate (SOUR)
· Were residuals form aerobically digested treatment (Inspection)? Yes No
· Were residuals 2% or less total solids (dry weight basis) (not diluted)? Yes No
· Was the test done between 10°C (50°F) and 30°C (86°F)? Yes No
· Was the temperature corrected to 20°C (68°F)? Yes No
· Was the SOUR equal to or less than 1.5 mg of oxygen per hour per gram of total residual solids (dry
weight basis)? Yes No
· Was the sampling holding time two hours? Yes No
· Was the test started within 15 minutes of sampling or aeration maintained? Yes No

Option 5 – 14-Day Aerobic Process
· Were the residuals from aerobically digested treatment (Inspection)? Yes No
· Were the residuals treated for 14 days? Yes No
· Was the residuals temperature higher than 40°C (104°F) for a 14-day period? Yes No
· Was the average residuals temperature higher than 45°C (113°F)? Yes No

Option 6 – Alkaline Stabilization
· Was the pH of the residuals raised to 12 or higher by the addition of alkali? Yes No
· Did the pH of residuals remain at 12 or higher for two hours without the addition of more alkali?
Yes No
· Did the pH of residuals remain at 11.5 or higher for an additional twenty-two hours without the
addition of more alkali? Yes No
· Was the pH corrected to 25°C (77°F)? Yes No

Option 7 – Drying of Stabilized Residuals
· Does the residuals contain any unstabilized residuals? Yes No
· Were the residuals mixed with any other materials? Yes No
· Were the residuals dried up to 75% total solids? Yes No

Option 8 – Drying of Unstabilized Residuals
· Were the residuals mixed with any other materials? Yes No
· Were the residuals dried to 90% total solids? Yes No

Option 9/10 – Injection/Incorporation
· Was there any significant amount of residuals on land surface one hour after injection (Inspection)?
Yes No
· Was injection done on pasture or hay field? Yes No
· Was injection done at time that crop was growing? Yes No
· If Class A with respect to pathogen, were residuals injected with eight hours after discharge from
pathogen treatment? Yes No
· Was incorporation done six hours after application (Inspection)? Yes No

4. General
• Was the report in the proper format? Yes No
• Was the annual report complete? Yes No
• Was the report submitted on time? Yes No
Pollutant Limits
Pollutant Ceiling
Concentration
Below
Limit
Cumulative
Pollutant
Loading Rate
Below
Limit
Arsenic 75 41
Cadmium 85 39
Copper 4300 1500
Lead 840 300
Mercury 57 17
Molybdenum 75 N/A
Nickel 420 420
Selenium 100 100
Zinc 7500 2800

TCLP
Parameter Below
Limit
Parameter Below
Limit
Parameter Below
Limit
Arsenic (5.0) 1,4-Dichlorobenzene (7.5) Nitrobenzene (2.0)
Barium (100.0) 1,2-Dichloroethane (0.5) Pentachlorophenol (100.0)
Benzene (0.5) 1,1-Dichloroethylene (0.7) Pyridine (5.0)
Cadmium (1.0) 2,4-Dinitrotoluene (0.13) Selenium (5.0)
Carbon tetrachloride (0.5) Endrin (0.02) Silver (5.0)
Chlorodane (0.03) Hepatachlor (and its
epoxide) (0.008)
Tetrachloroethylene (0.7)
Chlorobenzene (100.0) Hexachlorobenzene (0.13) Toxaphene (0.5)
Chloroform (6.0) Hexachlorobutadiene (0.5) Trichloroethylene (0.5)
Chromium (5.0) Hexachloroethane (3.0) 2,4,5-Trichlorophenol
(400.0)

m-Cresol (200.0) Lead (5.0) 2,4,6-Trichlorophenol (2.0)
o-Cresol (200.0) Lindane (0.4) 2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0) Mercury (0.2) Vinyl Chloride (0.2)
Cresol (200.0) Methoxychlor (10.0)
2,4-D (10.0) Methyl ethyl Ketone (200.0)

Residuals Analysis
Parameter Analyzed For Parameter Analyzed For Parameter Analyzed For
Aluminum Mercury Potassium
Ammonia-
Nitrogen
Molybdenum Selenium
Arsenic Nickel Sodium
Cadmium Nitrate-
Nitrite
Nitrogen
SAR
Calcium % TS TKN
Copper pH Zinc
Lead Phosphorus
Magnesium PAN

y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
Only required to collect once per permit cycle, before 2029.