WQ0019960_CEIARR_20210728

SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED
July 28, 2021

Brant Sikes
Email: [e-mail]
Marion, NC 28752

SUBJECT: Compliance Inspection Report-Annual Report Review
City of Marion RLAP
Non-discharge Permit No. WQ0019960
McDowell County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the City of Marion RLAP on
7/28/2021. This inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in Non-discharge Permit No. WQ0019960. 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: Tim Horton, ORC
Zach Keys, US Biosolids
Compliance Inspection Report
Permit:WQ0019960 Effective:08/01/16 Expiration:07/31/21 Owner :City of Marion
SOC:
Contact Person:
Region:
County:
Directions to Facility:
McDowell
Asheville
Heather Cotton
Effective:Expiration:Facility:City of Marion RLAP
3982 Hwy 226 S
Marion NC 28752
Title:Phone:[phone]
From ARO: I-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
Secondary ORC(s):
336-957-7869Phone:23629Certification:David W KeyPrimary ORC:
LA,System Classifications:
On-Site Representative(s):
Related Permits:
NC0031879 City of Marion - Corpening Creek WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
07/28/2021 11:19AM 12:30PM
Mikal Willmer 828-296-4686
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Land Application 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:
WQ0019960
07/28/2021 Annual Report Review
City of Marion
Routine
Inspection Summary:
Mikal Willmer, with the Asheville Regional Office, conducted a review of the Town of Marion’s RLAP Residuals Annual Report
on July 28, 2021. This review was conducted to determine whether the program is being operated and maintained in
compliance with Permit No. WQ0019960.
Approximately 58 dry tons were land applied to 6 of the 8 permitted fields in 2020. Fields K1 & K2 will be removed from the
permit at the request of the permittee.
As a reminder, any fields used as grazed pasture shall have the realistic nitrogen rate reduced by 25%. Based on the most
recent permit application all fields are listed as pasture. Additionally, all livestock shall remain off the field for 30 days
following land application.
Non-hazardous waste characterization: Required once per permit cycle. TCLP, ignitibility, corrosivity and reactivity results
were sampled in 2021 and were included with the renewal application. TCLP results referenced on ETS’ report of analysis
for 2020 were not included with annual report. Please include all results in future submittals even if sampling more frequently
than required by permit.
Pathogen and Vector Attraction Reduction: Facility met pathogen reduction by Alt. 1 Fecal Density and vector attraction
reduction through Alt.4 SOUR.
Page 2 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0019960
07/28/2021 Annual Report Review
City of Marion
Routine
Type Yes No NA NE
Distribution and Marketing
Land Application
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?
PAN limits listed on FSF correspond to soil series and crop, but should be reduced by 25% for
any fields utilized as pasture.
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)
Temperature corrected
Page 3 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0019960
07/28/2021 Annual Report Review
City of Marion
Routine
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
Facility utilizes SOURComment:
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
Comment:
Page 4 of 4