WQ0031674_More Information (Requested)_20210308

March 8, 2021
BOB BOYETTE – CITY MANAGER CITY OF MARION
POST OFFICE DRAWER 700 MARION, NORTH CAROLINA 28752-0700
Subject: Application No. WQ0031674
Additional Information Request City of Marion DCAR Distribution of Class A Residuals McDowell County
Dear Mr. Boyette:
Division of Water Resources’ Central and Regional staff has reviewed the application package received December 14, 2020. However, additional information is required before the review may be completed. Please address the items on the attached pages no later than the close of business on April 7, 2021.
Please be aware that you are responsible for meeting all requirements set forth in North Carolina rules and regulations. Any oversights that occurred in the review of the subject application package are still the Applicant’s responsibility. In addition, any omissions made in responding to the outstanding items
in Sections A through H, or failure to provide the additional information on or before the above requested date may result in your application being returned as incomplete.
Please reference the subject application number when providing the requested information. All revised and/or additional documentation shall be signed, sealed and dated (where needed), with an electronic copy submitted to my attention at the address below. If you have any questions regarding this request, please do not hesitate to contact me at [phone] or [e-mail]. Thank you for your cooperation.
Sincerely,
Lauren Raup-Plummer, P.E., Engineer III Division of Water Resources
cc: Asheville Regional Office, Water Quality Regional Operations Section (Electronic Copy) Zach Key – U.S. Biosolids, Inc. (Electronic Copy) Permit Application File WQ0031674
Mr. Bob Boyette March 8, 2021 Page 2 of 3

A. Application:
1. The response to Item IV.6 indicates that the facility does not have a stormwater management plan, but the provided explanation indicates that all runoff is directed to the ponds where the residuals are stored. Per our regional staff, the ponds were approaching capacity in 2019, and it is unclear
whether a distribution event occurred in 2020. The submitted documents indicate that distribution events occur when the ponds are at full capacity; however, it is unclear what determines full capacity (i.e. freeboard). Please provide additional information regarding operations under increased precipitation conditions, particularly with regards to maintaining freeboard in the residuals ponds.
B. Application Fee:
1. Not applicable.
C. Cover Letter:
1. No comment.
D. Program Information
1. As mentioned in comment A.1, it is unclear what benchmark is used to trigger a distribution event. Please provide clarification within the program information document.
E. Detailed Plans and Specifications:
1. Not applicable.
F. Engineering Calculations:
1. The 5-year PAN calculations were not provided. Please provide the 5-year PAN calculations.
G. Environmental Assessments
1. Not applicable.
H. Operation & Maintenance Plan:
1. Within the Operation & Maintenance Plan, it lists that TCLP sampling will be conducted once per
permit cycle. Our records indicate that the City of Marion DCAR is still on annual sampling and a permit modification request for reduced monitoring has not been received. Please revise the TCLP sampling period to reflect the current frequency (annual).
Mr. Bob Boyette March 8, 2021 Page 3 of 3
2. Within the provided spill control plan, the plan focuses on spills created during residuals transfer, and it is unclear what protocols are in place for overflows in the holding ponds. The notes within
the application indicated that all stormwater management is performed by directing flows to the holding ponds, but with holding ponds nearing capacity for residuals storage it appears that this possibility needs to be addressed. From the submitted documentation it is unclear whether there
are any discharge lines from the existing storage ponds. Please provide additional information regarding the control, containment, and remediation of upsets and bypasses within the storage areas pursuant to 15A NCAC 02T .1110(a)(4).
3. Within the O&M plan, a discrete inspection plan was not provided. Please provide an inspection plan including all necessary contact information.
Certificate Of Completion
Envelope Id: 6D7093FC33894D918888F73E284CAA55 Status: Completed
Subject: Please DocuSign: WQ0031674a210308.pdf
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