WQ0003698_Additional Information Request_20220408

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
J. ROBERT BOYETTE — CITY MANAGER
CITY OF MARION
POST OFFICE DRAWER 700
MARION, NORTH CAROLINA 28752
Dear Mr. Boyette:
NORTH CAROLINA
Environmental Quality
April 8, 2022
Subject: Application No. WQ0003698
Additional Information Request
Corpening Creek Surface Disposal
Units
Surface Disposal of Residuals
McDowell County
Division of Water Resources' Central and Regional staff has reviewed the application package
received January 10, 2022. 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 May 9,
2022.
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 E, or failure to provide the additional information on or before the above requested
date may result in your application being returned as incomplete pursuant to 15A NCAC 02T .0107(e)(2).
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 response submitted to my attention at: https://edocs.deq.nc.gov/Fonns/NonDischarge-Branch-
Submittal-Form-Ver2.
If you have any questions regarding this request, please contact me at [phone] or
[e-mail]. Thank you for your cooperation.
Sincerely,
—ZC 15az"W'Ie�
Erick Saunders, Engineer
Division of Water Resources
cc: Asheville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Laserfiche File (Electronic Copy)
E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CAROLINA -
OepaMlent at EnulmnmeMal Duality 919.707.9000

Mr. J. Robert Boyette
April 8, 2022
Page 2 of 3
A. Cover Letter:
1. No comments.
B. Surface Disposal of Residuals (FORM: SDR 06-16) Form:
1. No comments.
C. Site Assessment:
Asheville Regional Office (ARO) staff were notified on October 22, 2021 by the City of Marion's
Public Works Director, Brant Sikes, that recent construction activities uncovered a previously
unknown surface disposal unit. Subsequent site inspections by ARO staff in October and November
2021 found two additional surface disposal units that were unaccounted for. None of the three units
appear to correspond to the location of sludge pits 1 through 10 shown on the August 28, 2006
revised site survey map that was submitted in this renewal application. In addition, review of the
previous permits and the permit file suggests the existence of an additional lined pit, referred to as
Pit No. 11 in the January 10, 2001 permit issuance, which was not depicted on this site survey map.
There have been groundwater standard violations at monitoring wells MW-2 and MW-3 that were
noted in the March 3, 2022 Notice of Violation (NOV) NOV-2022-LV-0130. The incomplete maps
and uncertainty regarding the extent of these pits make it difficult to fully assess the causes and
extent of the contamination. As a condition of the renewed permit, a comprehensive site assessment
will be required in order to fully delineate all surface disposal units on site to establish accurate
waste boundaries, groundwater compliance/review boundaries, the condition/depth of the cover
material, the depth of each pit, the approximate volume of residuals, and the vertical separation of
the pits to the seasonal high water table (SHWT). Please provide a general timetable to accomplish
a comprehensive site assessment which meets the above criteria.
D. Site Map:
See Item C. 1. An updated site map shall be submitted with the general locations of all residuals
surface disposal areas, including the three recently discovered sites and Pit No. 11. The historical
names of these pits shall be used as identifiers if possible. Please note that the complete site
assessment for this site mentioned in Item C. 1. is not required to satisfy this condition. This map
shall show the location and general extent of the newly discovered units with their relation to the
known sites and the monitoring wells listed in Attachment C.
E. Operation and Maintenance (O&M):
1. Please provide a historic timeline of operations for the surface disposal pits on this site. This shall
include the dates that each individual pit was approved, when it was constructed, and the years that
it was operational. Please also provide a timeline and description of any other operations have been
performed on this site in proximity to the surface disposal units.
2. It was noted by ARO staff that the three previously unknown surface disposal units referenced in
Item C. 1. are only partially capped, with areas of uncovered exposed residuals observed during site
inspections. Additionally, there is a mature tree stand located at these sites, inhibiting proper

Mr. J. Robert Boyette
April 8, 2022
Page 3 of 3
inspection and maintenance on the site and a violation of Condition III.6. of the current permit. A
plan shall be submitted for the proper closure and maintenance of these new sites.
3. In accordance with 15A NCAC 02T .1109(d)(3), the post closure plan shall include a description
of the system used to monitor the air for methane gas in the air in any structures within the surface
disposal unit boundary and at the property line of the surface disposal unit. The table on pages 5
and 7 of the O&M Plan mention methane monitoring, but it does not include a description of the
system. Please provide an update to the O&M Plan describing this system.