WQ0031674_CEIARR_20220418

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

April 18, 2022

Brant Sikes
Email: [e-mail]
City of Marion

SUBJECT: Compliance Inspection Report
Annual Report Review 2021
City of Marion DCAR
Non-discharge Permit No. WQ0031674
McDowell County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the City of Marion’s DCAR Annual
Report on 4/18/2022. This inspection was conducted to verify that the facility is operating in compliance with
the conditions and limitations specified in Non-discharge Permit No. WQ0031674. 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. In future submittals, please include a cover letter that includes a list of the
attached items, a summary of the previous year’s operation and relevant contact information.

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
DocuSign Envelope ID: 989DB9E7-4254-488A-BA53-C267B10DC6F8
Compliance Inspection Report
Permit:WQ0031674 Effective:06/02/21 Expiration:01/31/27 Owner :City of Marion
SOC:
Contact Person:
Region:
County:
Directions to Facility:
McDowell
Asheville
Heather Cotton
Effective:Expiration:Facility:City of Marion DCAR
801 Old Greenlee Rd
Marion NC 28752
Title:Phone:[phone]
Secondary ORC(s):
Phone:Certification:Primary ORC:
System Classifications:
On-Site Representative(s):
Related Permits:
NCG590032 City of Marion - Marion WTP
NC0055221 City of Marion - Marion WTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
04/18/2022 12:00PM 12:25PM
Mikal Willmer 828-296-4686
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Distribution of Residual Solids (503 Exempt)
Annual Report Review
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Pathogen and Vector Attraction
(See attachment summary)
Page 1 of 4
DocuSign Envelope ID: 989DB9E7-4254-488A-BA53-C267B10DC6F8
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0031674
04/18/2022 Annual Report Review
City of Marion
Routine
Inspection Summary:
Mikal Willmer, with the Asheville Regional Office, conducted a review of the City of Marion’s WTP DCAR Annual Report on
April 18, 2022. This review was conducted to determine whether the facility processed and monitored all residuals in
compliance with Permit No. WQ0031674.
US Biosolids distributed approximately 44.12 dry tons of WTP residuals in 2021 on behalf of the City of Marion for use as a
soil amendment.
Pathogen and Vector Attraction Reduction are not required for water treatment plant residuals provided they do not meet the
definition of “Biological Residuals”.
Metals, Nutrients and Pollutants of Concern: Required annually based on tons distributed. All parameters appear to have
been sampled, reported and in compliance with permit requirements.
Non-Hazardous Waste Characterization: Required annually. TCLP, corrosivity, reactivity and ignitibility appeared to be within
regulatory limits.
Page 2 of 4
DocuSign Envelope ID: 989DB9E7-4254-488A-BA53-C267B10DC6F8
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0031674
04/18/2022 Annual Report Review
City of Marion
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 alum residuals. Can be distributed to the general public.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
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
Page 3 of 4
DocuSign Envelope ID: 989DB9E7-4254-488A-BA53-C267B10DC6F8
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0031674
04/18/2022 Annual Report Review
City of Marion
Routine
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench-top Aerobic/Anaerobic digestion results
PVAR is not required for WTP residuals that do not meet the definition of a biological residual.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
WTP alum residuals which are partially dried within the alum pond before distribution.Comment:
Page 4 of 4
DocuSign Envelope ID: 989DB9E7-4254-488A-BA53-C267B10DC6F8