WQ0031674_More Information (Received)_20210331

Non -Discharge Branch Upload/Submittal Form
Initial Review
Reviewer
Thornburg, Nathaniel
Is this submittal an application? (Excluding additional information.)*
C Yes 6' No
If not an application what is the submittal type?*
Permit Number (IR)*
Applicant/Permittee
Email Notifications
Does this need review by the hydrogeologist?*
Regional Office
CO Reviewer
Admin Reviewer
✓ Annual Report
✓ Residual Annual Report
• Additional Information
✓ Other
WQ0031674
City of Marion
• Yes s No

Submittal Form
Project Contact Information
Rease provide information on the person to be contacted by NEB Staff regarding electronic subnittal, confirmation of receipt, and other correspondence.
Name*
Zach Key
Email Address*
[e-mail]
Project Information
Application/Document Type *
✓ New (Fee Required)
✓ Modification - Major (Fee Required)
✓ Renewal with Major Modification (Fee
Required)
✓ Annual Report
c Additional Information
✓ Other
Phone Number*
3369577871
O Modification - Minor
O Renewal
O GW-59, NDMR, NDMLR, NDAR-1,
NDAR-2
✓ Residual Annual Report
✓ Change of Ownership
We no longer accept these monitoring reports through this portal. Please click on the link below and it will take you to the correct form.
https://edocs.deg.nc.gov/Forms/NonDischarge_Monitoring_Report
Permit Type:*
✓ Wastewater Irrigation
✓ Other Wastewater
✓ Closed -Loop Recycle
✓ Single -Family Residence Wastewater
Irrigation
✓ High -Rate Infiltration
✓ Reclaimed Water
t: Residuals
✓ Other
Permit Number:* WQ0031674
I- s CLrrent Existing permit number
Applicant/Permittee Address* PO Office Drawer 700 Marion, NC 28752-0700
Facility Name * City of Marion DCAR
Please provide comments/notes on your current submittal below.
At this time, paper copies are no longer required. If you have any questions about what is required, please contact Nathaniel Thornburg
at [e-mail].
Please attach all information required or requested for this submittal to be reviewed here.*
(Application Fora} Engineering Flans, Specifications, Calculations, 13c.)
WQ0031674 Add Info.pdf 467.54KB
Woad only 1 RFdocument (less than 250 M3). Mitiple documents rust be corrbined into one FDFfile unless file is larger than
upload lint.
*17 By checking this box, I acknowledge that I understand the application will not be
accepted for pre -review until the fee (if required) has been received by the Non -
Discharge Branch. Application fees must be submitted by check or money order
and made payable to the North Carolina Department of Environmental Quality
(NCDEQ). I also confirm that the uploaded document is a single PDF with all parts
of the application in correct order (as specified by the application).
Mail payment to:
NCDEQ — Division of Water Resources
Attn: Non -Discharge Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Signature
Submission Date 3/31/2021

rink
U.S. 13 osoiids
Monday, March 29, 2021
Lauren Plummer
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Reference: Additional Information Request
Application No. WQ0031674
City of Marion
Distribution of Class A Residuals
Dear Ms. Plummer:
PO Box 146 Ronda, NC 28670
336-777-6909
www.usbiosolids.com
In a letter received from the Division of Water Resources, additional information was requested
concerning the review of the permit renewal package of Permit WQ0031674. This letter requested four
pieces of additional information.
This first item was concerning the capacity and runoff of the residual ponds. The City of Marion did have
a distribution event that occurred in November of 2020 that reduced the amount of residuals in the
ponds. The only stormwater that the ponds collect is the rainwater that directly fall into or on the banks
of the ponds. The City of Marion does have drainage pipes in the ponds that can be used to drain excess
water from the ponds.
The second issue is what benchmark triggers a distribution event. A distribution event is planned when
the freeboard of the residuals reaches the three-foot mark from the full mark of one of the ponds, or
75% capacity. The Water Plant has two ponds so one can remain in service while the other is prepared
for a distribution event. This information has been added to the program information form that has
been included with this letter.
The third item is concerning the 5-year PAN Calculation. This calculation has been updated and an
updated RSC 06-16 form, with calculation sheet has been included with this letter.

The fourth, and final piece of information requested was an updated O&M plan. This O&M plan has
been updated to reflect the following changes and in included with this letter:
• The frequency of the TCLP testing has been changed to reflect annual testing when a land
application event occurs.
• Updated Spill Control plan for overflows in the holding ponds.
• Updated inspection plan with the necessary contact information.
if you have any questions or concerns, please do not hesitate to contact me at my direct line at 336-957-
7871 or at [e-mail].
Sincerely,
'iz.,
Zach Key
US Biosolids, Inc.

DWR
Division of Water Resources
State of North Carolina
Department of Environmental Quality
Division of Water Resources
RESIDUALS SOURCE CERTIFICATION
INSTRUCTIONS FOR FORM: RSC 06-16
Please use the following instructions as a checklist in order to ensure all required items are submitted. Adherence to these
instructions and checking the provided boxes will help produce a quicker review time and reduce the amount of additional
information requested. Failure to submit all of the required items will lead to additional processing and review time for the
permit application. Unless otherwise noted, the Applicant shall submit one original and two copies of the application and
supporting documentation
For more information, visit the Water Quality Permitting Section's Non -Discharge Permitting Unit
General — This certification provides detailed information of residuals source generating facility and its residuals quality for land
application, distribution, or disposal in accordance with 15A NCAC 02T .1 100. Do not submit this certification for review without
a corresponding application form (FORM: RLAP 11-15, FORM: DCAR 11-15, or FORM: SDR 11-15).
Unless otherwise noted, the Applicant shall submit one original and two copies of the application and supporting documentation listed
below.
A. Residuals Source Certification (FORM: RSC 1 1-15):
❑ Submit the completed and appropriately executed Residuals Source Certification (FORM: RSC 1 1-15) form. Please do not
make any unauthorized content changes to this form. If necessary for clarity or due to space restrictions, attachments to the
application may be made, as long as the attachments are numbered to correspond to the section and item to which they refer.
❑ For new or renewed permits, submit a separate certification for each source facility.
❑ For modified permits, submit a separate certification for only those facilities that are affected by the proposed modification.
O Complete the residuals source facility summary page. List all new, renewed, or modified facilities.
B. Residuals Source -Generating Facility Information:
❑ For each source facility, attach the following:
❑ Vicinity map - A vicinity map that shows the location of the facility and meets all of the criteria in the Map Guidance for_
Residuals Land Application Permits".
❑ Process flow diagram and/or narrative - A detailed narrative and/or process flow diagram that describes how the residuals
are to be generated, treated, processed, and stored at the facility.
❑ Quantitative justification for residuals production rate - A quantitative justification for the value provided in [tem I. 8.
Ensure that the amount of residuals listed is the maximum amount expected to be generated by the facility for the life of
the permit. In addition, ensure that this amount is equivalent to that which is actually to be land applied, distributed,
and/or disposed, including any chemicals, amendments, or other additives that are added to the residuals during
processing.
❑ Sampling plan - A detailed sampling plan for the residuals source -generating facility. Ensure that the plan identifies
sampling points, sampling frequency, sample type, as well as the Division -certified laboratory to be used. In addition,
ensure that the plan details how the facility and/or the residuals are monitored for any applicable pathogen reduction and
vector attraction reduction requirements. Note that all sampling and monitoring must be completed on the residuals as
they are to be land applied, distributed, and/or disposed.
C. Residuals Quality Information:
❑ For each source facility, attach the following:
❑ Laboratory analytical reports and operational data - reports for all laboratory analyses used to complete this certification.
❑ Documentation that the facility complies and/or the residuals comply with any applicable pathogen reduction and vector
attraction reduction requirements.
❑ For new facility that may have not yet been constructed and analytical results of residuals cannot be obtained, please
attach analytical results of residuals generated from a similar facility along with the description of similarities of the two
facilities.
INSTRUCTIONS FOR FORM: RSC 06-16 Page 1 of 1

RESIDUALS SOURCE FACILITY SUMMARY
Applicant's name: City of Marion, NC
Status
Code a
Facility Permit Holder
Facility Name
County
Permit Number
Maximum Dry Tons Per Year
Current''
Proposed
City of Marion
Marion Water Treatment
Plant
McDowell
WQ0031674
300
300
a Status Code for source facility are: ♦ N (New) • R (Renewed) ♦ M (Modified) • D (Deleted)
h The amount of residuals currently permitted for distribution. ]and application, or disposal (i.e, not applicable to new facility).
SUMMARY FOR FORM: RSC 06-16
Page 1

DWR
Division of Water Resources
State of North Carolina
Department of Environmental Quality
Division of Water Resources
RESIDUALS SOURCE CERTIFICATION
FORM: RSC 06-16
I. RESIDUALS SOURCE -GENERATING FACILITY INFORMATION (See Instruction B.):
I. Facility Name: City of Marion Water Treatment Plant
2. Facility permit holder is: 0 Federal, 0 State, El Local Government, or [] Private.
Facility permit issued by: 0Div. of Water Resources, Q Div. of Environmental Health,
or 0 Other (explain: ).
3. Facility contact person and title: Brant Sikes
Complete mailing address: PO Drawer 700
City: Marion State: NC Zip: 28752-0700
Telephone number: [phone] E-mail address: bsikes a,marionnc.org
4. Facility physical address: 801 Old Greenlee Road
City: Marion State: NC Zip: 28752
Coordinates: Latitude: 35' 41' 04" Longitude: 82 02' 34"
Datum: NAD83 Level of accuracy:.01
Method of measurement: MAP
5. Purpose of the facility:
0 treatment of municipal wastewater, 0 treatment of 100% domestic wastewater,
treatment of potable water, 0 treatment of 100% industrial wastewater,
treatment of industrial wastewater mixed with domestic wastewater,
(approximate percentages: % industrial and % domestic)
0 other (explain: ).
6. Does the facility have an approved pretreatment program: D Yes
7. Facility permitted/design flow: 4 MGD and facility average daily flow: 1.45 MGD
8. Average amount of residuals being generated at this facility 30 dry tons per year.
9. Specify the following regarding treatment and storage volumes available at the facility:
Type and volume of residuals treatment: two (2) 250,000 gallon ponds
Type and volume of residuals storage (i.e., outside of residuals treatment units): None
II. RESIDUALS QUALITY INFORMATION (See Instruction C.):
I. Specify if residuals are regulated under:
Q 40 CFR Part 503 or E 40 CFR Part 257.
Note: Only residuals that are generated during domestic/municipal wastewater treatment processes are regulated under 40
CFR Part 503, otherwise, the residuals are regulated under 40 CFR Part 257.
2. Specify if residuals are defined under 15A NCAC 02T.1 102(6) as:
Biological Non -Biological
Note: Biological residuals are residuals that have been generated during the treatment of domestic wastewater, animal
processing wastewater, or the biological treatment of industrial wastewater (biological treatment is a system that utilizes
biological processes including lagoons, activated sludge systems, extended aeration systems, and fixed film systems).
FORM: RSC 06-16 Page 1 of 5

3. Hazardous Waste Determination: Complete the following to demonstrate that the residuals are non -hazardous under
RCRA: (Note - this item does not have to be completed for facilities that are less than 0.5 MGD in design flow that treat
100% non -municipal, domestic wastewater only)
a. Are the residuals listed in 40 CFR §261.31-§261.33: ❑ yes ► l no.
If yes, list the number(s):
b. Specify whether or not the residuals exhibit any of the characteristics defined by 40 CFR §261.21-
261.24: ❑ yes
►ai
no.
Fill in the following tables with the results of the latest toxicity characteristic leaching procedure (TCLP) analysis as
well as those for corrosivity, ignitability, and reactivity:
Laboratory: Pace Analytical and Date of analysis: 11/30/2020
Passed corrosivity test: ►",/ yes 0 no. pH: s.u. (2 < pH < 12.5)
Passed ignitability test: yes ❑ no. Flashpoint: 200 °F (> 140°F)
Passed reactivity test: /1 yes ❑no. HCN: ND mg/kg (<250) & H2S: ND mg/kg (<500)
TCLP Parameter
Limit
(mg/1)
Result
(mg,/1)
TCLP Parameter
Limit
(mg/1)
Result
(mg/l)
Arsenic
5.0
ND
Hexachlorobenzene
0.13
ND
Barium
100.0
ND
Hexachloro-1,3-Butadiene
0.5
ND
Benzene
0.5
ND
Hexachloroethane
3.0
ND
Cadmium
1.0
ND
Lead
5.0
ND
Carbon Tetrachloride
0.5
ND
Lindane
0.4
ND
Chlordane
0.03
ND
Mercury
0.2
ND
Chlorobenzene
100.0
ND
Methoxychlor
10.0
ND
Chloroform
6.0
ND
Methyl Ethyl Ketone
200.0
ND
Chromium
5.0
ND
Nitrobenzene
2.0
ND
m-Cresol
200.0
ND
Pentachlorophenol
100.0
ND
o-Cresol
200.0
ND
Pyridine
5.0
ND
p-Cresol
200.0
ND
Selenium
1.0
ND
Cresol
200.0
ND
Silver
5.0
ND
2,4-D
10.0
ND
Tetrachloroethylene
0.7
ND
1,4-Dichlorobenzene
7.5
ND
Toxaphene
0.5
ND
I,2-Dichloroethane
0.5
ND
Trichloroethylene
0.5
ND
1,1-Dichloroethylene
0.7
ND
2,4,5-Trich lorophenol
400.0
ND
2,4-Dinitrotoluene
0.13
ND
2,4,6-Trichlorophenol
2.0
ND
Endrin
0.02
ND
2,4,5-TP (Silvex)
1.0
ND
Heptachlor and its Hydroxide
0.008
ND
Vinyl Chloride
0.2
ND
FORM: RSC 06-16
Page 2 of 5

4. Metals Determination: Complete one of the following tables (i.e., as applicable) to demonstrate that the residuals do not
violate the ceiling concentrations for metals regulated under 15A NCAC 02T .1105.
a. For Distribution/Land Application: Fill in the following table with the results of the latest analyses (i.e., on a dry weight
basis) for the following metal parameters:
Laboratory: Waypoint Analytical and Date of analysis: 11/12/2020
Parameter
Ceiling
Concentration Limits
(ClassA & ClassB)
(mg/kg)
Monthly Average
Concentration Limits
(Class A Only)
(mg/kg)
Result
(mg/kg)
Arsenic
75
41
35.7
Cadmium
85
39
7.14
Copper
4,300
1,500
35.7
Lead
840
300
21.4
Mercury
57
17
1.07
Molybdenum
75
n/a
17.9
Nickel
420
420
17.9
Selenium
100
100
35.7
Zinc
7,500
2,800
89.3
b. For Surface Disposal Unit (landfill): Fill in the following table with the results of the latest analyses (i.e., on a dry weight
basis) for the following metal parameters:
Laboratoryand Date of analysis:
Distance from Disposal
Unit to Boundary to
Closest Property Line
(meters, check one)
Arsenic
(mg/kg)
Chromium
(mg/kg)
Nickel
(mg/kg)
d > 0 but < 25
30
200
210
34
220
240
® > 25 but < 50
IJ > 50 but < 75
39
260
270
46
300
320
> 75 but < 100
tj > l00 but < 125
53
360
390
Q > 125
62
450
420
Result (mg/kg)
FORM: RSC 06-16
Page 3 of 5

5. Nutrient/Micronutrient Determination: Complete the following:
a. Total solids: 1.42 %.
b. Fill in the following table with the results of the latest analyses (i.e., on a dry weight basis) for the following nutrient and
micronutrient parameters:
Laboratory: Waypoint Analytical and Date of analysis: 1 1 / 1 2/2020
Parameter
Result
Ong/kg)
Aluminum
174000
Ammonia -Nitrogen
20600
Calcium
3570
Magnesium
2000
Nitrate -Nitrite Nitrogen
356
pH (Standard Unit)
5.9
Phosphorus
1290
Potassium
1890
Sodium
1790
Total Kjeldahl Nitrogen
28300
c. Using the results listed in tem 1I. 5b. above, calculate the sodium adsorption ration (SAR): 0.7
[Note: If residuals contain SAR of 10 or higher, the applicant shall obtain recommendations from the local Cooperative
Extension Office, the Department of Agriculture and Consumer Services, the Natural Resource Conservation Service, a
North Carolina Licensed Soil Scientist, or an agronomist, prior to land application of residuals. The recommendations shall
address the sodium application rate, soil amendments (e.g., gypsum, etc.), or a mechanism for maintaining site integrity
and conditions conducive to crop growth].
d. Specify the mineralization rate to be used in calculating the plant available nitrogen (PAN) of the residuals: 40 %. This
rate is a (check one): El default value, or 0 actually established.
If the residuals are not generated from the treatment of municipal or domestic wastewater, explain or provide technical
justification as to why the selected default value is appropriate to be applied to these residuals: Non -Processed Residuals
e. Calculate the PAN for the residuals (i.e., on a dry weight basis) and fill the results in the following table:
Application Method
First (I") Year PAN
Ong/kg)
Five -Year
Maximum Adjusted PAN
(mg/kg)
Surface
13736
18587.27
Injection/Incorporation
24036
25456.34
6. Other Pollutants Determination: Specify whether or not there are any other pollutants of concern in the residuals and provide
the results of the latest analyses: None
FORM: RSC 06-16
Page 4 of 5

7. Pathouen Reduction: Per I5A NCAC 02T. 1106, specify how residuals will meet the pathogen reduction requirements:
a. For Distribution/Land Application of Class A or Equivalent:
• A fecal coliform density that is demonstrated to be less than 1,000 MPN per gram of total dry solids,
or
• A salmonella sp. density that is demonstration to be less than 3 MPN per 4 grams of total dry solids.
AND one of the followings (except for non -biological residuals):
ID Alternative I [I5A NCAC 02T.I I06(b)(3)(A)] - Time/Temperature Compliance.
EY. Alternative 2 [15A NCAC 02T.I I06(b)(3)(B)] - Alkaline Treatment.
El Alternative 3 [15A NCAC 02T.1 106(b)(3)(C)] - Prior Testing for Enteric Virus/Viable Helminth Ova.
• Alternative 4 [15A NCAC 02T.1106(b)(3)(D)] - No Prior Testing for Enteric Virus/Viable Helminth Ova.
O Alternative 5 [15A NCAC 02T.1 106(b)(3)(E)-(K)] - Process to Further Reduce Pathogens (PFRP).
Specify one: 0 composting, 0 heat drying, 0 heat treatment,
thermophilic aerobic digestion, ] beta ray irradiation,
O gamma ray irradiation, or Ej pasteurization.
b. For Land Application of Class B:
O Alternative I [15A NCAC 02T.1 106(c)(I)] - Fecal Coliform Density Demonstration.
O Alternative 2 [15A NCAC 02T.1 106(c)(2)] - Process to Significantly Reduce Pathogens (PSRP).
Specify one: 0 aerobic digestion, 0 air drying, 0 anaerobic digestion,
O composting, or ] lime stabilization.
c. For Surface Disposal:
O Select One of the Class A or Equivalent Pathogen Reduction Alternatives in Item II. 7a. above.
ID Select One of the Class B or Equivalent Pathogen Reduction Alternatives in Item II. 7b. above.
Exempt - If Daily Cover Alternative is chosen in Item 11.8. below [15A NCAC 02T.1 106(a)(2)].
1�t
Not Applicable - Non -Biological Residuals with NO Domestic Wastewater Contribution.
8. Vector Attraction Reduction (VAR): Per I5A NCAC 02T. 1107, specify how residuals will meet the VAR requirements:
Alternative 1 [15A NCAC 02T.1 107(a)(1)] - 38% Volatile Solids Reduction (Aerobic/Anaerobic Digestion).
0 Alternative 2 [15A NCAC 02T.1 107(a)(2)] - 40-Day Bench Scale Test (Anaerobic Digestion).
0 Alternative 3 [1SA NCAC 02T.1 107(a)(3)] - 30-Day Bench Scale Test (Aerobic Digestion).
Ej Alternative 4 [I5A NCAC 02T.1 107(a)(4)] - Specific Oxygen Uptake Rate Test (Aerobic Digestion).
• Alternative 5 [15A NCAC 02T.1 107(a)(5)] - 14-Day Aerobic Processes.
Ej Alternative 6 [I5A NCAC 02T.1 107(a)(6)] - Alkaline Stabilization.
0 Alternative 7 [I5A NCAC 02T.I 107(a)(7)] - Drying of Stabilized Residuals.
0 Alternative 8 [15A NCAC 02T.I 107(a)(8)] - Drying of Unstabilized Residuals.
0 Alternative 9 [15A NCAC 02T.1 107(a)(9)] - Injection.
O Alternative 10 [I5A NCAC 02T.1 107(a)(I0)] - Incorporation.
0 Alternative for Surface Disposal Units Only - Soil/Other Material Cover [15A NCAC 02T.I 107(b)(2)].
• Not Applicable - Non -Biological Residuals with NO Domestic Wastewater Contribution.
Note: For animal processing residuals, only alternatives 9 or 10 may be chosen due to the nuisance conditions that typically
occur when these residuals are applied and left on the land surface.
FORM: RSC 06-16
Page 5 of 5

Year 1
Year 2
Year 3
Year 4
Year 5
Total
(Ibs PAN/a
PAN surface
13736 mg/Kg 27.472 Ibs/ton
PAN iinjettiion
24036 mg/kg 48.072 Ibs/tan
Surface
TKN
PAN
PAN
Remaining
organic nitrogen
(mg/Kg)
(mg/Kg)
(Ibs/DT)
(mg/Kg)
28300
13736
27.472
14564
14564
2912.8
5.8256
11651.2
11651.2
1165.12
2.33024
10486.08
10486.08
524.304
1.048608
9961.776
9961.776
249.0444
0.498089
9712.732
18587.27
.37.17454
Operations log calcs
Data date = 11/19/2020
Ammonia - nitrogen
Mineralization rate =
NO2-NO3-N
TKN
20600
0.4
356
28300
mg/Kg
mg/Kg
mg/Kg
Injection
TKN
PAN
PAN
Remaining organic
nitrogen
(mg/Kg)
(mg/Kg)
(lbs/DT)
,Remaining
28300
24036
48.072
4264
4264
852.8
1.7056
3411.2
3411.2
341.12
0.68224
3070.08
3070.08
153.504
0.307008
2916.576
2916.576
72.9144
0.145829
2843.6616
25456.34
50.91268.
total Certified tons/yr
300 total tons
Assumed
Rate
Acres required 1 -year
Surface Inject
Acres required 5 -year
Surface Inject
(acres)
(acres)
50
164.832
288.432
223.0472
305.4761
100
82.416
144.216
111.5236
152.738
150
54.944
96.144
74.34907
101.8254
200
41.208
72.108
55.76181
76.36902

Program Information
All of the residuals produced from the City of Marion's Water Treatment plant are stored
in the two (2), two hundred fifty thousand (250,000) gallon sludge storage ponds. The residuals
are produced from the treatment of raw water from the Clear Creek, Mackey Creek, and Buck
Creek.
The first location during the treatment that the residuals are produced is from the
sedimentation basins, from where the residuals are allowed to settle out. The return water left in
the sedimentation basin is pumped to the sludge holding ponds.
The second place in the treatment process that produced residuals are from the filtration.
The filters are backwashed and the residuals from the backwash process are sent to the sludge
holding ponds. Also residuals are sent to the ponds when a filter is rewashed during plant start-
up.
Once the residuals reach the sludge holding ponds, they are stored until the ponds are full
enough to need a distribution event. A distribution event is needed once one of the ponds reach
75% full or three foot from the full mark.
Once it is determined that a distribution event is needed, the residuals are removed using
a dredge and loaded onto tanker trucks for transport to local landowners. The residuals are given
to local landowner's for use as a soil amendment.
All of the residual are stored in the sludge holding ponds along with any leachate or run
off the may be present.
All land owners that receive the residuals are given an information sheet that will
explain all of the requirements and regulations for the material. This information sheet will also
highlight any nutrients that will be the limiting parameter for determining the residuals loading
rate. In most cases, the limiting parameter for determining the loading rate will be nitrogen.

Operation and Maintenance Plan
City of Marion Water Treatment Plant
In accordance with the requirements as issued by the North Carolina Department of
Environmental and Natural Resources using NCGS 143-215.1 and 143-215.3(a) based on
15A NCAC 02T .110, the City of Marion and U.S Biosolids, Inc. is implementing this
Operation and Maintenance Plan.
The Class A distribution program from the City of Marion Water Treatment Plant
will be conducted from the Water Treatment facility, located at 801 Old Greenlee Road
Marion, NC. Residuals will be removed and given away to local farmers to be used as a
soil amendment. The residuals will be removed on as needed bases as fluctuation in the
output of the plant will vary with changing economic conditions. The day-to-day
operation of the running of the Water Treatment will be conducted by the City of Marion.
The operations of the distribution program will be conducted by U.S Biosolids, Inc.
A label shall be provided to every recipient of the residual material, in addition to this
label, the ORC will make sure every recipient is educated in the proper use of the
residuals.
Prior to distributing these residuals to local farmers, the following sampling conditions
must be met (as is outlined in greater detail in the sampling plan attached to this
Operation and Maintenance Plan).
Toxicity Characteristics Leaching Procedure (TCLP) will be conducted once per
year, if a distribution event takes place.
An analysis of the parameters will be conducted annually if a distribution event
takes place.
These samples will be collected by the ORC or his/her designee and transported to an
approved lab the same day the samples are taken, as in accordance with 15A NCAC 02B
.0505. The samples must be taken in a matter to ensure a representative sample of the
residuals has been taken.
An inspection will be conducted will be conducted daily while a distribution event is
taking place. This inspection will confirm that all requirements of permit WQ0031 b74
are complying. The fields should be inspected daily for compliance with the conditions
that is outline in then permit. The inspection should consist of (but not limited to):
1. All required setbacks and buffers are complying.
2. All required record keeping of truck and fields sheets are maintained and properly
filled out so accurate records of the volume and locate of residuals are keep.
3. All public access points are controlled (signs posted, gates closed)
4. Make sure all fields' records are turned over to the ORC and the City of Marion
so records can be reviewed by NCDEQ and an annual report can be constructed.

If any issues or violations are discovered, the ORC, Marion Water Treatment Plant and
the Asheville Regional Office should be contacted as soon as safely possible.
This inspection will be conducted by the following personal:
o On Site Project Manager, US Biosolids, Inc. 336-957-7878
o Ben Worley, City of Marion 828-652-2428
To prevent any spills and or safety issues from occurring the flowing will take place
during a distribution event. In the unlikely event of a spill consult the spill control plan
immediately.
1. Access to the facility will be controlled with a locked gate and signs to
prevent any unauthorized entry into the complex; this gate will be lock at the
end of each day.
2. All pumps and hose will be checked at the start of each day for leaks or loose
fittings.
3. All tanker valves are closed prior to loading and lids are closed prior to
transport.
4. All dump trailers or dump trucks gates are tightly fastened and do not leak
prior to transport.
5. All on road equipment is check as per DOT regulations for any safety or
mechanical hazards or issues.
6. All equipment is secured at the end of each working day to prevent any
tampering or unauthorized use.
7. Enough freeboard is maintained in the residual ponds so that heavy
precipitation events does not cause a spill due to the ponds overflowing. This
can be accomplished by maintaining the levels of residuals to an acceptable
level.
8. If enough freeboard cannot be maintained, residuals may have to be pumped
and transported to the Wastewater Treatment Plant so that the ponds do not
overflow.

SPILL CONTROL PLAN- U.S Biosolids, Inc.
CITY OF MARION-WATER TREATMENT PLANT
In the event of a spill, the following should be taken IMMEDITALY.
1. Make sure all personal and bystanders are safe; if not, contact emergency services
without delay.
2. Halt the source of the spill- overturned truck, leaking valve, ruptured tank,
overflow from holding ponds.
3. Contain the spill. Use straw bales or earthen barrier to form a dike to contain the
spill.
4. Cleanup. Employ vacuum trucks, dump trucks, and loaders to remove as much of
the spilled material as possible. Use straw to soak -up the remaining material.
Dispose of the same in a landfill.
5. Flush the roadways with water if needed. If the spill occurred on a tillable area,
till the same into the soil and spread lime if necessary. If a spill occurs on private
property, final clean-up should be to the satisfaction of the owner.
6. Notification. (This should be done as soon as safely possible.)
U.S Biosolids, Inc. Main Office [phone]
City of Marion Water Treatment Plant [phone]
NCDEQ, Asheville Regional Office [phone]
County/City Emergency Services (Sheriff, Fire Dept.) 911
7. The Permittee shall report by telephone to the Mooresville Regional Office,
telephone number [phone], as soon as possible, but in no case more than
24 hours or on the next working day following the occurrence or first knowledge
of the occurrence of any of the following:
A. Surface disposal of residuals abnormal in quantity or characteristic.
B. Any failure of the surface disposal program resulting in a release of
material to surface waters.
C. Any time self -monitoring indicates the facility has gone out of compliance
with its permit limitations.
D. Any process unit failure, due to known or unknown reasons, rendering the
facility incapable of adequate residual treatment.

E. Any spill or discharge from a vehicle or piping system during residuals
transportation.
Any emergency requiring immediate reporting (e.g., discharges to surface waters,
imminent failure of a storage structure, etc.) outside of normal business hours shall be
reported to the Division's Emergency Response personnel at telephone number (800)
662-7956, [phone], or [phone]. Persons reporting such occurrences by
telephone shall also file a written report in letter form within five days following first
knowledge of the occurrence. This report shall outline the actions taken or proposed to be
taken to ensure that the problem does not recur.
8. Spill Prevention. The easiest way to clean a spill is to prevent one.
A. Ensure loading personal watch the vehicle being loaded.
B. Ensure all valves and lids are closed.
C. Inspect all seals and replace if necessary.

CITY OF MARION
WTP SAMPLING PLAN
Annually, if a distribution event occurs, grab samples are collected from
the two residual ponds. Samples from the ponds will be combined to form individual grab
samples to be sent to a laboratory for analysis. If a distribution event is to occur in the
early part of a calendar year (i.e. January or early February) these samples may have to be
taken in December so results can be obtained before the land application event, as some
results take 30+ days to receive.
These individual grab samples are collected and tested for fecal coliform analysis,
nutrient analysis, and a TCLP test. These tests will be taken by Zach Key of U.S.
Biosolids, Inc. All samples except for the composite residual sample will be taken to
Statesville Analytical, the composite residual sample will be sent to Waypoint Analytical.
All samples taken will be taken in the same condition as the residuals are to be land
applied.
Annually, if land application occurs, a composite residual sample will be
analyzed, prior to a land application event for:
Cadmium, Copper, Lead, Mercury, Molybdenum, Nickel, Selenium, Zinc,
Aluminum, Ammonia Nitrogen, Calcium, Nitrate Nitrogen, Magnesium, % total Solids,
pH, Phosphorus, Potassium, TKN, Sodium
From this information, the Plant Available Nitrogen (PAN) and a Sodium
Absorption Ratio (SAR) will be calculated. This sample will be collected in a non-
breakable container, at least one quart in size. This sample will be taken from the
clarifier.
A Toxicity Characteristics Leaching Procedure (TCLP) test with ignitability,
reactivity, and corrosivity will be collected in two, one -gallon jugs. This test will be
conducted on a frequency as outlined in permit WQ0031674.