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Home My WebLink AboutWQ0031674_CEI_20210216 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED February 18, 2021 Brant Sikes, Public Works Director Email: bsikes@marionnc.org City of Marion SUBJECT: Compliance Inspection Report Marion WTP Non-discharge Permit No. WQ0031674 McDowell County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Marion WTP on 2/05/2021. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in Non-discharge Permit No. WQ0031674. 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 me at 828-296-4686 or via email at mikal.willmer@ncdenr.gov. 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: E005D7C2-87E6-48D4-BDDA-20F54E3941C3 Compliance Inspection Report Permit:WQ0031674 Effective:06/01/16 Expiration:05/31/21 Owner :City of Marion SOC: Contact Person: Region: County: Directions to Facility: McDowell Asheville Brant Sikes Effective:Expiration:Facility:Marion WTP Greenlee Rd NCSR 1214 Marion NC 28752 Title:Phone:828-652-4224Public Works Director Secondary ORC(s): Phone:Certification:Primary ORC: System Classifications: On-Site Representative(s): Related Permits: NC0055221 City of Marion - Marion WTP Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 02/05/2021 09:30AM 10:30AM Mikal Willmer 828-296-4686 Lauren E Armeni Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Routine Distribution of Residual Solids (503 Exempt) Compliance Evaluation Question Areas: Miscellaneous Questions Record Keeping Treatment Storage (See attachment summary) Page 1 of 5 DocuSign Envelope ID: E005D7C2-87E6-48D4-BDDA-20F54E3941C3 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0031674 02/05/2021 Compliance Evaluation City of Marion Routine Inspection Summary: Mikal Willmer and Lauren Armeni, with the Asheville Regional Office, conducted a compliance evaluation inspection of the Marion WTP distribution program on February 5, 2021. This inspection was conducted in conjunction with the facility's permit renewal. Ben Worley, WTP ORC, was present and assisted in the inspection. At the time of the inspection, the facility was found to be compliant with DCAR Permit No. WQ0031674. No distribution events occurred from 2014 to 2020. The City contracts with US Biosolids to dredge and distribute their alum residuals. Samples were collected for analysis in November 2020 in preparation for a distribution event in early 2021. All paperwork is maintained in binders within the WTP. The most recent TCLP, pollutant parameters and SAR values appeared to be within permit limits. At the time of the inspection, some of the alum residuals from pond #2 had been dredged and distributed on a nearby field. According to the ORC, the City did not have additional distribution events scheduled for the fiscal year due to funding. Inspectors noted most of the alum residuals remained in ponds 1 & 2. The ORC is requesting additional funding in the upcoming budget cycle for more frequent removal of the WTP residuals. Please note, while it is not a permit requirement to distribute residuals annually, the City should attempt to dispose of the alum residuals on a more frequent basis. Allowing both ponds to fill completely between application events significantly reduces the wastewater storage capacity within the alum ponds, increasing the risk to the stream and potentially affecting the water treatment process. The City’s permit application is currently under review. When the draft permit is received, carefully review any listed changes from your permit issued in 2016. . Page 2 of 5 DocuSign Envelope ID: E005D7C2-87E6-48D4-BDDA-20F54E3941C3 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0031674 02/05/2021 Compliance Evaluation City of Marion 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? A distribution event occurred for the first time this year since 2013. 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 No treatment of residuals. This is a water treatment plant. Facility has two alum holding ponds.Comment: Page 3 of 5 DocuSign Envelope ID: E005D7C2-87E6-48D4-BDDA-20F54E3941C3 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0031674 02/05/2021 Compliance Evaluation City of Marion Routine ALUM SLUDGE POND Storage Yes No NA NE Storage Type?Pond Storage amount?250000 Gallons Is storage aerated or mixed?NONE If aeration is present, is it adequate? If present, are diffusers cleaned regularly? Is influent structure acceptable? Are banks/berms free of seepage and erosion? Are banks/berms free of excessive vegetation? Is lagoon lined? Liner Type Full, clay Is liner acceptable? Are baffles/curtains acceptable? Does the lagoon have a freeboard marker? Required freeboard? Actual freeboard? Is there suitable grassed vegetation? Is the vegetation maintained? Is the area free of excessive weeds and/or woody species? Is the area free from signs of overflow? Is storage free of excessive solids build-up? Are aerators/mixers acceptable? Is residuals loading area maintained? Is there a Spill Control Plan? This is a clay lined alum pond. No free board marker is required since a telescoping valve is used to control the direct discharge to the creek under the facilitiy's general NPDES permit. Vegetation is regularly mowed along the pond banks. No signs of erosion or bare spots forming along the banks. Alum sludge was applied for first time since 2013. See summary for details. Comment: ALUM SLUDGE POND #2 Storage Yes No NA NE Storage Type?Pond Storage amount?250000 Gallons Is storage aerated or mixed?NONE Page 4 of 5 DocuSign Envelope ID: E005D7C2-87E6-48D4-BDDA-20F54E3941C3 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0031674 02/05/2021 Compliance Evaluation City of Marion Routine If aeration is present, is it adequate? If present, are diffusers cleaned regularly? Is influent structure acceptable? Are banks/berms free of seepage and erosion? Are banks/berms free of excessive vegetation? Is lagoon lined? Liner Type Full, clay Is liner acceptable? Are baffles/curtains acceptable? Does the lagoon have a freeboard marker? Required freeboard? Actual freeboard? Is there suitable grassed vegetation? Is the vegetation maintained? Is the area free of excessive weeds and/or woody species? Is the area free from signs of overflow? Is storage free of excessive solids build-up? Are aerators/mixers acceptable? Is residuals loading area maintained? Is there a Spill Control Plan? See Alum Pond #1 and summary.Comment: Page 5 of 5 DocuSign Envelope ID: E005D7C2-87E6-48D4-BDDA-20F54E3941C3 Certificate Of Completion Envelope Id: E005D7C287E648D4BDDA20F54E3941C3 Status: Completed Subject: Please DocuSign: WQ0031674_CEI insp.pdf, WQ0031674_CEI.docx Source Envelope: Document Pages: 6 Signatures: 1 Envelope Originator: Certificate Pages: 2 Initials: 2 Mikal Willmer AutoNav: Enabled EnvelopeId Stamping: Enabled Time Zone: (UTC-05:00) Eastern Time (US & Canada) 217 W. Jones Street Raleigh, NC 27699 Mikal.willmer@ncdenr.gov IP Address: 149.168.204.10 Record Tracking Status: Original Feb 18, 2021 | 10:25 Holder: Mikal Willmer Mikal.willmer@ncdenr.gov Location: DocuSign Security Appliance Status: Connected Pool: StateLocal Storage Appliance Status: Connected Pool: North Carolina Department of Environmental Quality Location: DocuSign Signer Events Signature Timestamp Mikal Willmer mikal.willmer@ncdenr.gov Environmental Specialist North Carolina Department of Environmental Quality Security Level: Email, Account Authentication (None) Signature Adoption: Pre-selected Style Using IP Address: 149.168.204.10 Sent: Feb 18, 2021 | 10:27 Viewed: Feb 18, 2021 | 10:27 Signed: Feb 18, 2021 | 10:27 Electronic Record and Signature Disclosure: Not Offered via DocuSign Lauren Armeni lauren.armeni@ncdenr.gov North Carolina Department of Environmental Quality Security Level: Email, Account Authentication (None)Signature Adoption: Pre-selected Style Using IP Address: 149.168.204.10 Sent: Feb 18, 2021 | 10:27 Viewed: Feb 18, 2021 | 10:27 Signed: Feb 18, 2021 | 10:28 Electronic Record and Signature Disclosure: Not Offered via DocuSign In Person Signer Events Signature Timestamp Editor Delivery Events Status Timestamp Agent Delivery Events Status Timestamp Intermediary Delivery Events Status Timestamp Certified Delivery Events Status Timestamp Carbon Copy Events Status Timestamp Witness Events Signature Timestamp Notary Events Signature Timestamp Envelope Summary Events Status Timestamps Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted Feb 18, 2021 | 10:27 Certified Delivered Security Checked Feb 18, 2021 | 10:27 Signing Complete Security Checked Feb 18, 2021 | 10:28 Completed Security Checked Feb 18, 2021 | 10:28 Payment Events Status Timestamps