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Home My WebLink AboutWQ0019960_CEIARR_NOD2022PC0081_20220531_20220531 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED May 31, 2022 Brant Sikes Email: bsikes@marionnc.org City of Marion SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2022-PC-0081 Permit No. WQ0019960 City of Marion RLAP McDowell County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the City of Marion RLAP on May 31, 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. WQ0019960. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Annual Report Review inspection was conducted by Division of Water Resources staff from the Asheville Regional Office. The following deficiency was noted during the inspection: Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________ Record Keeping The City land applied residuals that exceeded the ceiling concentratio n for molybdenum. Per Section II.5 of the permit, pollutant concentrations in residuals land applied to permitted sites shall not exceed ceiling concentration limits. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: 62111087-035C-4A68-AFFD-5CCF280C36BE Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. To prevent further action, carefully review these deficiencies and address the causes of non-compliance to prevent the recurrence of similar situations. If you should have any questions, please do not hesitate to contact Mikal Willmer with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4686 or via email at mikal.willmer@ncdenr.gov. Sincerely, G. Landon Davidson, P.G., Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: LF Tim Horton, ORC DocuSign Envelope ID: 62111087-035C-4A68-AFFD-5CCF280C36BE Compliance Inspection Report Permit:WQ0019960 Effective:08/12/21 Expiration:10/31/27 Owner :City of Marion SOC: Contact Person: Region: County: Directions to Facility: McDowell Asheville Brant Sikes Effective:Expiration:Facility:City of Marion RLAP 3982 NC 226 S Marion NC 28752 Title:Phone:828-652-4224 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): Phone:Certification:Primary 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: 05/31/2022 10:00AM 11:12AM 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 DocuSign Envelope ID: 62111087-035C-4A68-AFFD-5CCF280C36BE Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0019960 05/31/2022 Annual Report Review City of Marion Routine Inspection Summary: Mikal Willmer, with the Asheville Regional Office, completed the review of the Town of Marion’s 2021 RLAP Annual Report on May 31, 2022. This review was conducted to determine whether the facility processed and monitored all residuals in compliance with Permit No. WQ0019960. The Town land applied approximately 103 dry tons of Class B residuals to 4 of six permitted fields. Pathogen Reduction (PR): PR is met through Process to Significantly Reduce Pathogens-Lime Stabilization. Vector Attraction Reduction (VAR): The city meets VAR via SOUR and/or Alkaline Stabilization. Pollutants of Concern: The City’s residuals exceeded the ceiling concentration for Molybdenum and were land applied. Molybdenum was reported as 93.3 mg/kg. It should be noted, per section II.5 of the permit, residuals land applied shall not exceed the ceiling concentration of any pollutant. The ceiling concentration of Molybdenum is 75 mg/kg. Metals & Nutrients: All metals and nutrient parameters were analyzed per section IV.3 of the permit. PAN and SAR are being reported on the residuals sampling summary form. Soil Fertility Analysis: ESPs were below 15. Lime was applied to field R1 as recommended on the report. Non-hazardous waste characterization: Required once per permit cycle. The City has met the requirement for the permit cycle and all results appear to be compliant. Page 2 of 4 DocuSign Envelope ID: 62111087-035C-4A68-AFFD-5CCF280C36BE Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0019960 05/31/2022 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? Residuals applied to fescue. See summary for details.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: 62111087-035C-4A68-AFFD-5CCF280C36BE Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0019960 05/31/2022 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 Facility also utilizes SOUR as a secondary Vector Attraction reudction method.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 Comment: Page 4 of 4 DocuSign Envelope ID: 62111087-035C-4A68-AFFD-5CCF280C36BE