WQ0002127_RI_20220613

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

June 13, 2022

Eli Self
ORC
Email: [e-mail]
City of Morganton

SUBJECT: Reconnaissance Inspection Report
City of Morganton DCAR
Non-discharge Permit No. WQ0002127
Burke County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the City of Morganton DCAR
on 6/08/2022. This inspection was conducted to verify that the facility is operating in compliance with
the conditions and limitations specified in Non-discharge Permit No. WQ0002127. 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 with the Water
Quality Regional Operations Section in the Asheville Regional Office at 828-296-4653 or via email at
[e-mail].

Sincerely,

Melanie Kemp, Environmental Specialist I
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report

E.c.: LF

DocuSign Envelope ID: 5E52D441-DCB6-47D5-AF96-68FF25159697
Compliance Inspection Report
Permit:WQ0002127 Effective:05/18/21 Expiration:02/28/23 Owner :City of Morganton
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Burke
Asheville
Eli Self
Effective:Expiration:Facility:City of Morganton DCAR
1000 Vine Arden Rd
Morganton NC 28655
Title:Phone:[phone]ORC
I-40 to Exit 105 to Hwy. 18N. Turn rt. on Hwy. 70 By-Pass, turn left @ light to Hwy. 70 W. Turn right on Kirksey Dr. Go approx. 1.25
miles to Vine Arden Road on right.
Secondary ORC(s):
Phone:Certification:Primary ORC:
System Classifications:
On-Site Representative(s):
Related Permits:
NC0026573 City of Morganton - Catawba River Pollution Control Facility
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
06/08/2022 10:00AM 12:30PM
Mikal Willmer 828-296-4686
Melanie Kemp Phone :
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Distribution of Residual Solids (503)
Reconnaissance
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Sampling Pathogen and Vector Attraction Storage
(See attachment summary)
Page 1 of 4
DocuSign Envelope ID: 5E52D441-DCB6-47D5-AF96-68FF25159697
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0002127
06/08/2022 Reconnaissance
City of Morganton
Routine
Inspection Summary:
Mikal Willmer and Melanie Kemp, with the Asheville Regional Office, conducted a compliance evaluation inspection of the
Morganton Compost facility on June 9, 2022. This inspection was conducted as a non-routine maintenance inspection
related to DCAR Permit No. WQ0002127. City of Morganton Staff were present and assisted with the inspection.
Overall, the facility appeared to be in compliance. A summary of observations, recommendations and comments noted at
the time of the inspection are below.
Initial Solids Processing: Recommend improved solids handling, including a study to evaluate the current capacity and
ability to meet growing demands.
Solids are transported from the centrifuges to the mixing shed. The City has not purchased a mixing box; however, they are
using two separate front-end loaders to reduce potential contamination. One loader is specifically designated for mixing and
the other for end-product. A mixing box, while not required, may aid compost staff in obtaining a consistent mixture when
constructing piles. The City maintains approximately a 3 to 1 wood chips to sludge mixing ratio and aim for approximately
55% TS before transferring to bays for aeration. Staff report %TS is not analyzed every time and is based on staff’s
knowledge. The City attempts to minimize any potential contamination and maintain quality control by using only one wood
chips supplier. Approximately 1 foot of cover is placed over each of the 16 beds in rotation.
Piles are aerated and monitored for at least 14 days with the blowers set to cycle on and off at predetermined intervals. The
corrugated pipes used for aeration under the piles are replaced once a year. Pipes are covered with a layer of woodchips
when replaced. Return chips from screening are used as an insulating cover over the piles.
Four spots of each pile are monitored for temperature daily (3 at 12 inches deep and 1 at 18 inches deep). Compost staff
take measurements during the week and WWTP operators are responsible for measurements during the weekends. Mr.
Self, ORC, indicated all staff are trained on the proper temperature monitoring protocol (appropriate depths and locations).
Two thermometers are available for staff to use.
Power Screen: The power screen is approximately 17 years old and in need of replacement. Staff reported they have been
able to get replacement parts for the items needed so far; however, they indicated any major component failure may render it
inoperable and require complete replacement. It is recommended a new power screen be incorporated into the budget to
ensure continuity of compost operations for the foreseeable future.
Sampling: Cross-sectional samples are taken of the screened product over a two week period to obtain a representative
sample. Samples are delivered to Statesville Analytical for analysis. Staff autoclave the stainless-steel sample scoop used
to collect composite samples of the final pile. Facility staff stated they utilize food-grade bags, but the ARO recommends
utilizing sterilized bags for sample collection to reduce the potential for cross-contamination. Please reference Standard
Methods Section 9030 B Equipment Specifications.
Operation and Maintenance: Please make the following changes to the O&M Plan:
-Include temperature collection depths, discussed above, in section 2.0
-Update aeration time period from 21 to “at least 14 days”, based on current operations (sections 3.0 and 4.0).
-Add a note to sampling protocol about resampling process for if/when initial results are above permit standards.
Storage: Additional covered storage is recommended for the final product, to reduce the reintroduction of moisture before
distribution.
Page 2 of 4
DocuSign Envelope ID: 5E52D441-DCB6-47D5-AF96-68FF25159697
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0002127
06/08/2022 Reconnaissance
City of Morganton
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 products are distributed to the public, free of charge. No permit limit exists for PAN, but
is calculated and provided to consumers for application purposes. Distributation data and
results will be reviewed after the 2022 Annual Report is submitted in 2023. The first two quarter
results were reviewed on-site and monthly averages did not exceed permit limits.
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)
Page 3 of 4
DocuSign Envelope ID: 5E52D441-DCB6-47D5-AF96-68FF25159697
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0002127
06/08/2022 Reconnaissance
City of Morganton
Routine
Temperature corrected
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
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
Cetrifuged sludge is mixed with wood chips as a bulking agent to build compost piles. Piles are
static aerated to meet pathogen and vector attraction reduction. See summary for details.
Comment:
Sampling Yes No NA NE
Describe sampling:
Is sampling adequate?
Is sampling representative?
Facility collects composite samples from the compost pile after being screened. See summary
for additional details.
Comment:
Page 4 of 4
DocuSign Envelope ID: 5E52D441-DCB6-47D5-AF96-68FF25159697