WQ0002127_CEI_20210331

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

March 31, 2021

Brad E Boris
Email: [e-mail]
City of Morganton

SUBJECT: Compliance Inspection Report
City of Morganton DCAR
Non-discharge Permit No. WQ0002127
Burke County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the City of Morganton DCAR
on 3/10/2021. This inspection was conducted to verify that the facility is operating in compliance with
the conditions and limitations specified in Non-discharge Permit No. 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 me at 828-296-4686 or via email at
[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
Eli Self-ORC
DocuSign Envelope ID: F06A7C8F-91C5-46ED-8A01-22ED030864C4
Compliance Inspection Report
Permit:WQ0002127 Effective:03/01/18 Expiration:02/28/23 Owner :City of Morganton
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Burke
Asheville
Brad E Boris
Effective:Expiration:Facility:City of Morganton DCAR
1000 Vine Arden Rd
Morganton NC 28655
Title:Phone:[phone]Director Water Resources
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):
Phone:Certification:Primary 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:
03/11/2021 10:00AM 12:00PM
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)
Compliance Evaluation
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Sampling Pathogen and Vector Attraction Storage
(See attachment summary)
Page 1 of 4
DocuSign Envelope ID: F06A7C8F-91C5-46ED-8A01-22ED030864C4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0002127
03/11/2021 Compliance Evaluation
City of Morganton
Routine
Inspection Summary:
Mikal Willmer and Lauren Armeni, with the Asheville Regional Office, conducted a compliance evaluation inspection of the
Morganton Compost facility on March 10, 2021. This inspection was conducted to determine whether the facility is being
operated and maintained in compliance with DCAR Permit No. WQ0002127. City of Morganton Staff were present and
assisted in the inspection.
Overall, the facility appeared to be in compliance. A summary of observations, recommendations and comments noted at
the time of the inspection are below.
Initial Solids Processing: Recommend improved aeration for all sludge holding tanks to reduce odors and further aid the
breakdown of solids which would help improve storage capacity for processing. Staff were catching up on solids processing
because both centrifuges downstream of the holding tanks became inoperable at the same time.
Solids are transported from the centrifuges to the mixing shed. The City has not purchased a mixing box; however, they are
using two separate front-end loaders to reduce potential contamination. One loader is specifically designated for mixing and
the other for end-product. A mixing box, while not required, may aid compost staff in obtaining a consistent mixture when
constructing piles. The City maintains approximately a 3 to 1 wood chips to sludge mixing ratio and aim for approximately
55% TS before transferring to bays for aeration. Staff report %TS is not analyzed every time and is based on staff’s
knowledge. The City attempts to minimize any potential contamination and maintain quality control by using only one wood
chips supplier.
Piles are aerated for 21 days with the blowers set to cycle on and off at predetermined intervals. The corrugated pipes used
for aeration under the piles are replaced once a year. Pipes are covered with a layer of woodchips when replaced. Return
chips from screening are used as an insulating cover over the piles.
Four spots of each pile are monitored for temperature daily. Compost staff take measurements during the week and WWTP
operators are responsible for measurements during the weekends. Mr. Self, ORC, indicated all staff are trained on the
proper temperature monitoring protocol (appropriate depths and locations). Two thermometers are available for staff to use.
Power Screen: The power screen is approximately 16 years old and in need of replacement. Staff reported they have been
able to get replacement parts for the items needed so far; however, they indicated any major component failure may render it
inoperable and require complete replacement. It is recommended a power screen be incorporated into the budget to ensure
continuity of compost operations for the foreseeable future.
Sampling: Cross-sectional samples are taken of the screened product over a two week period to obtain a representative
sample. Samples are delivered to Statesville Analytical for analysis. Staff autoclave the stainless-steel sample scoop used
to collect composite samples of the final pile. Please verify the bags purchased for fecal coliform sampling are listed as
sterile by the manufacturer. If these bags are not listed by the manufacturer as “sterile”, then the bags needs to be sterilized
in the laboratory before use. Please reference Standard Methods Section 9030 B Equipment Specifications.
Operation and Maintenance: Additional covered storage area is recommended to reduce the reintroduction of moisture to
the piles. Staff clean the compost stormwater pump station approximately once a year during the summer to remove debris.
Additionally, please review the facilities operation and maintenance plan to verify all listed protocols are current practice and
update as needed.
Page 2 of 4
DocuSign Envelope ID: F06A7C8F-91C5-46ED-8A01-22ED030864C4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0002127
03/11/2021 Compliance Evaluation
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 distributed to the public for free. PAN is calculated for consumer information
purposes; however, no set permit limit as end use varies. 2020 Distirbution data and results will
be reviewed under a seperate report. The first quarter results for 2021 were reviewed during the
inspection. No nutrient limiting factor as receiving crop varies. Metals monthly average and
ceiling concentration limits are referenced to determine if distribution is allowed.
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)
Page 3 of 4
DocuSign Envelope ID: F06A7C8F-91C5-46ED-8A01-22ED030864C4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0002127
03/11/2021 Compliance Evaluation
City of Morganton
Routine
c. pH records for alkaline stabilization (Class B)
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
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
Thickened sludge from the centrifuges is mixed with wood chips (bulking agent) to build compost
piles. Facility utilizes static aerated compost piles to meet pathogen and vector attraction
reduction. See summary for details.
Comment:
Sampling Yes No NA NE
Describe sampling:
See below and summary.
Is sampling adequate?
Is sampling representative?
Facility takes cross-sectional samples of the compost as the pile is being built after screening.
See summary for additional details.
Comment:
Page 4 of 4
DocuSign Envelope ID: F06A7C8F-91C5-46ED-8A01-22ED030864C4
Certificate Of Completion
Envelope Id: F06A7C8F91C546ED8A0122ED030864C4 Status: Completed
Subject: Please DocuSign: WQ0002127_CEI.rpt.pdf, WQ0002127_CEI.ltr.docx
Source Envelope:
Document Pages: 5 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
[e-mail]
IP Address: 149.168.204.10
Record Tracking
Status: Original
Mar 31, 2021 | 07:24
Holder: Mikal Willmer
[e-mail]
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
[e-mail]
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: Mar 31, 2021 | 07:25
Viewed: Mar 31, 2021 | 07:25
Signed: Mar 31, 2021 | 07:25
Electronic Record and Signature Disclosure:
Not Offered via DocuSign
Lauren Armeni
[e-mail]
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: Mar 31, 2021 | 07:25
Viewed: Mar 31, 2021 | 08:33
Signed: Mar 31, 2021 | 08:33
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 Mar 31, 2021 | 07:25
Certified Delivered Security Checked Mar 31, 2021 | 08:33
Signing Complete Security Checked Mar 31, 2021 | 08:33
Completed Security Checked Mar 31, 2021 | 08:33
Payment Events Status Timestamps