WQ0019960_Regional Office Physical File Scan Up To 12/7/2022

' z _
NON-DISC"aRGEREGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
Date: 11/4/02
To: Non -Discharge Permitting Unit
NDPU Reviewer:
Regional Login No:
County: McDowell
Permitee: Marion, City of
Application No.: W00019960
GENERAL INFORMATION
1. This application is (check all.that apply): ❑ New ❑ Renewal
❑ Minor Modification ® Major Modification
❑ Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
Land Application of Residuals ® Attachment B included as appropriate E 503 regulated ❑ 503 exempt
❑ Distribution of Residuals ❑ Surface Disposal
2. Was a site visit conducted in order to prepare this report? ® Yes or ❑ No.
a. Date of site visit: 10/29/02
b. Person contacted and contact information: Caroline Edwards, Earthwise Designs, 828.247.0067
c. Site visit conducted by: Larry Frost and Qu Qi
d. Inspection Report Attached: ® Yes or ❑ No.
3. Is the following information entered into the BIMS record for this application correct?
® Yes or ❑ No. If no, please complete the following or indicate that it is correct on the current
application.
For Treatment Facilities:
a. Location: Current permit (NC0031879) information is correct.
b. Driving Directions:
c. USGS Quadrangle Map name and number:.
d. Latitude: Longitude-
e. Regulated Activities / Type of Wastes (e.g., subdivision, food processing, municipal wastewater):
Municipal Wastewater
For Disposal Sites:
(If multiple sites either indicate which sites the information applies to, copy and paste a new section
into the document for each site, or attach additional pages for each site)
a. Location(s): Wayne Ross site R2
b. Driving Directions: NC Highway 226 south of Marion turn west on NCSR 1775 Walker Road.
R2 is on the south side of Walker Road approximately 1 mile. Note: Rl is on the north side of
Walker Road.
c. USGS Quadrangle Map name and number: Dysartsville, NC — 35081-E7-TF-024
FORM: NDSRR 03/02 1

NON-DISCnARGE REGIONAL WATER. QUALITY
STAFF REPORT AND RECOMMENDATIONS
d. Latitude: 350 34'50" Longitude: 810 51'20"
a. Location(s): Voua Yang site Y1
b. Driving Directions: NC Highway 226 south of Marion turn east on NCSR 1769 Dysartsville
Road. Y1 is on the south side of Dysartsville Road approximately 1.5 miles.
c. USGS Quadrangle Map name and number: Dysartsville, NC — 35081-E7-TF-024
d. Latitude: 350 34'45" Longitude: 810 51'34"
a. Location(s): Frank Queen site Q1
b. Driving Directions: Exit I-40 at exit 94 onto Dysartsville Road south to Patton Road turn east.
Site is south of road approximately l mile, behind brick home and farm buildings.
c. USGS Quadrangle Map name and number: Glen Alpine — N3537.5-W8145/7.5
d. Latitude: 350 39'35" Longitude: 810 50' 10"
a. Location(s): Frank Queen site Q2
b. Driving Directions: Exit_ I-40 at exit 94 onto Dysartsville Road south to Patton Road turn east.
Site is south of road approximately 1 mile, behind brick home and farm buildings.
c. USGS Quadrangle Map name and number: Glen Alpine — N3537.5-W8145/7.5
d. Latitude: 350 39'35" Longitude: 810 49'50"
NEWAND MAJOR MODIFICA TION APPLICA TIONS (this section not needed for renewals or
minor modifications, skin to next section)
DESCRIPTION OF WASTE(S) AND FACILITIES
1. Please attach completed rating sheet. Facility Classification: IV
2. Are the new treatment facilities adequate for the type of waste and disposal system?
® Yes ❑ No ❑ N/A. If no, please explain:
3. Are the new site conditions (soils, topography, etc) consistent with what was reported by the soil
scientist and/or Professional Engineer? ® Yes ❑ No ❑ N/A. If no, please, explain:
4. Is the proposed residuals management plan for the adequate and/or acceptable to the Division.
® Yes ❑ No ❑ N/A. If no, please explain:
5. Are the proposed application rates for new sites (hydraulic or nutrient) acceptable?
FORM: NDSRR 03/02 2

NON-DISC1r�RGE REGIONAL WATE-, QUALITY
STAFF REPORT AND RECOMMENDATIONS
® Yes ❑ No ❑ N/A. If no, please explain:
6. Are the new treatment facilities or any new disposal sites located in a 100-year floodplain?
❑ Yes ® No ❑ N/A. If yes, please attach a map showing areas of 100-year f � odplain and please
explain and recommend any mitigative measures/special conditions in Part IV:
7. Are there any buffer conflicts (new treatment facilities or new disposal sites)? ❑ Yes or ® No. If
yes, please attach a map showing conflict areas or attach any new maps you have received from the
applicant to be incorporated into the permit:
RENEWAL AND MODIFICATIONAPPLICATIONS (use previous section for new or maior
modification systems)
DESCRIPTION OF WASTES) AND FACILITIES
1. Are there an appropriately certified ORCs for the facilities? ® Yes or ❑ No.
Operator in Charge: Dennis Kev Certificate #:15704
Back- Operator in Charge: David Kev Certificate #:23629
2. Is the design, maintenance and operation (e.g. adequate aeration, sludge wasting, sludge storage,
effluent storage, etc) of the treatment facilities adequate for the type of waste and disposal system?
® Yes or ❑ No. If no, please explain:
3. Are the site conditions (soils, topography, etc) maintained appropriately and adequately assimilating
the waste? ® Yes or ❑ No. If no, please explain:
4. Is the residuals management plan for the facility adequate and/or acceptable to the Division?
® Yes or ❑ No. If no, please explain:
5. Are the existing application rates (hydraulic or nutrient) still acceptable? ® Yes or ❑ No. If no,
please explain:
6. Are there any buffer conflicts (treatment facilities or disposal sites)? ❑ Yes or ® No. If yes, please
attach a map showing conflict areas or attach any new maps you have received from the applicant to
be incorporated into the permit:
7. Is the type and/or volume of waste(s) as written in the existing permit correct? ® Yes or ❑ No. If
no, please explain: _
8. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No. If no,
please explain:
9. Has a review of all self monitoring data been conducted? ® Yes or ❑ No. Please summarize any
findings resulting from this review:
FORM: NDSRR 03/02 3

NON-DISCnARGE REGIONAL WATEn QUALITY
STAFF REPORT AND RECOMMENDATIONS
10. Check all that apply: ® No compliance issues; ❑ Notice(s) of violation within the last permit cycle;
❑ Current enforcement action(s) ❑ Currently under SOC; ❑ Currently under JOC; ❑ Currently
under moratorium. If any items checked, please explain and attach any documents that may help
clarify answer/comments (such as NOV, NOD etc):
11. Have all compliance dates/conditions in the existing permit, SOC, JOC, etc. been complied with?
❑ Yes or ❑ No. If no, please explain: N/A
12. Are there any issues related to compliance/enforcement that should be resolved before issuing this
permit? ❑ Yes or ® No. If yes, please explain:
EVAL UATIONAND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.: none
2. List any items that you would like NDPU to obtain through an additional information request. Make
sure that you provide a reason for each item:
Item Reason
3. List specific Permit conditions that you recommend to be removed from the permit when issued.
Make sure that you provide a reason for each condition:
Condition Reason
4. List specific special conditions or compliance schedules that you recommend to be included in the
permit when issued. Make sure that you provide a reason for each special condition:
Condition Reason
FORM: NDSRR 03/02 4

NON-DISCIx-�RGE REGIONAL WATER. QUALITY
STAFF REPORT AND RECOMMENDATIONS
5. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office;
❑ Hold, pending review of draft permit by regional office; ® Issue; ❑ Deny. If deny, please state
reasons:
6. Signature of report preparer: Larry Frost
Signature of WQS regional supervisor: Forrest Westall
Date:
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: NDSRR 03/02 5

State of North Carolina
Department of Environment
_
and Natural Resources
Division of Water Quality,
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
NCDENR
Gregory J. Thrope, Ph.D., Acting Director
NCRTH CA s0_ NA DE:mr2TNENT OF
Eh1vi=2nKr.rCMT ANC N.&T.1RAL RrMn11=?(-rA
Non -Discharge Compliance Inspection
WQ Permit Number
WQ0019960
County
McDowell
Permittee
City of Marion Residuals
Application Program
Land Npdes Number(s)
NCO031879
NCO071200
Issuance Date
4/24/2002
Expiration Date
6/30/2006
Soc Issuance Date
Soc ExpirationDate
Permittee Contact
J. Robert Boyette
Phone Permittee Contact
828.652.8843
ORC Certification #
ORC Name
Larry Carver
Phone ORC
828.652.8843
24hr Contact Name
Larry Carver
Phone 24hr
828.652.8843
Reason For Inspection (Select One)
10 Routine 0 Complaint 0 Follow -Up
0 Other...
Type Of Inspection (Select One)
10 Collection System 0 Spray Irrigation
0 Residual
Inspection Summary
Mr.,..Qua.Qi..Qf..Glt'�S.ARQ.and..I..accclxi�anied..IV1a,..far.Qlxn�e..�dwarrl�.of.�arxh�nrise.Systexn�s..Qn.an..
inspe ti.Qlx.of...4..pr.Qpo;;ed..;:ite..to..be..added..tQ.the..tnARS..pr.Qsarm.forJhe.Gity..4f..1lllarian...All........
sites.aPPear 9..have.approprl..ate..bwffers..from..$treem$x.wetsa.gad. .exi$ting.s#rs?.�t�lre .ar�d.Weli;
Aii,sites,have, established„gound,cov„er„v„egetation,, fescue, pasture,, GWS..and.WQS.found..no......
problems with. teh, 4,sites„listed.beloW,.... ......... ......... ._....... ......... ........,
........................ ...............
..............................................................................................................................................................................................................................
7..-.Vlle�rr�e..�ase.site..-.b�GD�ell..aumty...........................................................................................................................
2.-.Jls�t�a�.Y.eeg..SAte. X1..-.1kIGlAcxvell.................................................................................................................................................
.-.xeinfc.4�ueen.cite.Q1..-.filarke.....................................................................................................................................................
...................................................................................................................................................
..............................................................................................................................................................................................................................
..............................................................................................................................................................................................................................
Inspector's Name Larr Frost
Phone Inspector 828.251.6208
Inspection Date 10/29/2002
Inspector's Title
Fax Inspector
Environmental Chemist
828.251.6452
page 1

Non Discha--"--a Compliance Residua'-'-ispection
Permittee ICity of Marion Residuals Land Application
Permit Number IWQ0019960
Inspection Date 10/29/2002
Type
* Land Application 0 Distribution and Marketing
Was a copy of current permit available?
Were current metals and nutrient analysis available? (see permit for frequency)
a. TCLP analysis?
b. SSFA ( Standard Soil Fertility Analysis)?
Were nutrient and metal loading calculated to determine most limiting parameters? YTD
Were hauling records available?
How many gallons / tons hauled during the calendar year to date?
Were field loading records available?
Were records of lime purchased available?
❑ Fields
❑ Pathogen and Vector Attraction Reduction (if applicable)
Were Operation and Manintance records present?
Were Operation and Manintance records Complete?
Has the land application equipment been calibrated?
Pathogen and Vector Attraction (if applicable):
10 Yes 0 No 0 N/A
0 Yes 0 No N/A
10 Yes 0 No N/A
10 Yes 0 No N/A
10 Yes 0 No N/A
10 Yes 0 No N/A
N/A
0 Yes 0 No N/A
10 Yes 0 No N/A
Yes 0 No N/A
O Yes 0 No * N/A
0-Ye—so No * N/A
a. Fecal coliform SM 9221 E ( Class A or B 10 Yes 0 No * N/A
0 ( Class A, all test must be <1000 MPN / dry gram )
0 (Geometric mean of 7 samples per monitoring period for Class B <2.0*106 CFU / dry gram )
.Fecal coliform SM 9222 D ( Class B only) 10 Yes 0 No DQ N/A
0 ( Geometric mean of 7 samples per monitoring period for Class B <2.0*106 CFU / dry gram )
b. Salmonella ( Class A, all tests must be < 3MPN / 4 grams dry) O Yes O No O� N/A
c. Time / Temp on: 10 Yes 0 No * N/A
❑ Digester ( MCRT) ❑ Compost ❑ Class A lime stabilization
d. Volatile Solids Calculations. 10 Yes 0 No 0 N/A
e. Bench -Top Aerobic/ Anaerobic digestion results. O Yes 0 No N/A
f. pH records fo Lime Stabilization (Class A or B). O Yes O No O� N/A
Treatment
Equipment
Additional
Equipment
® Aerobic Digestion ❑ Alkaline Stabilization (Other)
❑ Auto Thermophilic Aerobic Digestion ❑ Compost (Windrow)
❑ Anaerobic Digestion ❑ Compost (Aerated Static Pile)
❑ Drying Beds ❑ Other
❑ Alkaline Stabilization (Lime)
page 2

Non ®ischar-_- Compliance Residual ' spection
Permittee Icity of Marion Residuals Land Application
Permit Number WQ0019960
Inspection Date 10/29/2002
Transport
Was a copy of the permit in transport vehicle? PYes 0 No N/A
Was a copy of the spill control plan in vehicle? 0 Yes 0 No N/A
Did transport vehicle appear to be maintained? 10 Yes 0 No 0 NIA
Storage
❑ Lagoon 0 AST ❑ UST ❑ Septic Tank ❑ Drying Beds ❑ Concrete Storage Pads
How many months storage?
Was a copy of the spill control plan on site? 10 Yes 0 No Ds N/A
If Applicable:
Is lagoon lined? 10 Yes 0 No N/A
Above Ground Tank ® Aerated ❑ Mixed Aerated Hp: Mixed Hp:
Under Ground Tank ❑ Aerated ❑ Mixed I Aerated Hp: I Mixed Hp: I
Sampling_
Describe Sampling:
Was sampling adequate?
Was sampling representative?
Were buffers adequate?
Is the cover crop type specified in permit?
Were exceedence of PAN limits documented?
Was the application site in good condition?
Was the site free of runoff / ponding?
Was the acreage specified in the permit being utilized?
Was the application equipment present and operational?
Were there any limiting slopes on disposal field?
(10% for surface application)
(18% for subsurface application)
Are monitoring wells called for in permit?
Was there access restrictions and / or signage?
Was a copy of the permit on site during application events?
Was the application site free of odors or vectors?
Were nutrient / crop removal practices in place?
0 Yes 0 No N/A
O Yes 0 No NIA
IU Yes 0 No 0 N/A
Di Yes 0 No O N/A
0 Yes 0 No * N/A
Yes 0 No 0 N/A
0 Yes 0 No O NIA
0 Yes 0 No * N/A
0 Yes 0 No *N/A
0 Yes No 0 N/A
0 Yes 0 No 0 N/A
0 Yes *No 0 N/A
0 Yes 0 No OO NIA
0 Yes 0 No * N/A
0 Yes 0 No - N/A
O Yes 0 No OO NIA
page 3

GROUNDWATER SECTION
MEMORANDUM
November 4, 2002
TO: Larry Frost
Water Quality Section
Asheville Regional Office
THROUGH: Landon Davidson, Regional Groundwater Supervisor
Asheville Regional Office
FROM: Qu Qi v
Asheville Re ional Office
SUBJECT: Land Application of Residual Solids — Permit Modification
City of Marion - Corpening Creek WWTP
Permit Number WQ 0019960
McDowell County, North Carolina
I have reviewed the subject permit application and visited the proposed locations. All the
buffer requirements are met and the depths to seasonal high water tables are more than six (6)
feet. Issuance of the permit is recommended with the general condition that groundwater
monitoring as deemed necessary may be required
If you have any questions, please do not hesitate to call me at [phone] ext. 228.

flu%N A -FFR Michael F. Easley, Governor
William G. Ross Jr., Secretary
G1 North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
October 10, 2002
Mr. J. Robert Boyette
City Manager
City of Marion
PO Box 700
Marion, NC 28752
Subject: Acknowledgement of Application No. WQ0019960
City of Marion
Land Application of Residuals
McDowell County
Dear Mr. Boyette:
The Non -Discharge Permitting Unit of the Division of Water Quality (Division) acknowledges receipt of
your permit application and supporting materials on September 26, 2002. This application package has
been assigned the number listed above and will be reviewed by Shannon Thornburg.
The reviewer will perform a detailed review and contact you with a request for additional information if
necessary. To ensure the maximum efficiency in processing permit applications, the Division requests
your assistance in providing a timely and complete response to any additional information requests.
Please be aware that the Division's Regional Office, copied below, must provide recommendations prior to
final action by the Division. Please also note at this time, processing permit applications can take as long
as 60 - 90 days after receipt of a complete application.
If you have any questions, please contact Shannon Thornburg at 919-733-5083, extension 353, or via e-
mail at [e-mail]. If the reviewer is unavailable, you may leave a message, and
they will respond promptly.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES ON THIS
PROJECT.
Sincerely,
%A.
Kim H. Colson, P.E.
Supervisor
cc: Asheville Regional Office, Water Quality Section
Caroline Edwards, Earthwise Designs
Permit Application File WQ0019960
A! MA
Non -Discharge Permitting Unit Internet httpJ/h2o.enr.state.nc.uslndpu NCDENIF
1617 Mail Service Center, Raleigh, NC 27699-1617 Telephone [phone] Fax [phone]
DENR Customer Servipe Center Telephone [phone]
n., =�... I as,,. GrM01 nOl .,. �r— —t Imo, .;n—

OCT 9 4 NO2
CHARGE APPLICATION REVIEW REQUEST
Date: October 10, 2002
To: EQrrest Westall; ARO=WQS ❑ Debra Watts, CO-GWS
❑ Paul Rawls, FRO-WQS
❑ Rex Gleason, MRO-WQS Copies Sent to CO-GWS: 0
❑ Ken Schuster, RRO-WQS
❑ Jim Mulligan, WaRO-WQS
❑ Rick Shiver, WiRO-WQS espies Sent to RO=WQS::4�
❑ Steve Mauney, WSRO-WQS [E-Distribute 2iCopies_to ROmGWS
From: Shannon Mohr Thornburg , Non -Discharge Permitting Unit
Telephone: [phone] ext. 353 Fax: [phone]
E-Mail: [e-mail]
A. Permit Number: W00019960
B. Owner: City of Marion
C. Facility/Operation: Citv of Marion Residuals Land Application Program
❑
Proposed
® Existing ❑ Facility
® Operation
D. Application:
1. Permit Type: ❑
CS (O&M)
❑ Surface Irrigation ❑ Reuse
❑ H-R Infiltration
❑
Recycle
❑ I/E Lagoon ❑ GW Remediation (ND)
For Residuals:
® Land
App. ❑ D&M
❑ Surface Disposal
® 503
❑ 503 Exempt
❑ Animal
2. Project Type: ❑
New ® Major
Mod. ❑ Minor Mod. ❑ Renewal
❑ Renewal w/ Mod.
E. Comments/Other Information:
❑ I would like to accompany you on a
site visit.
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within 30 calendar days, please take the following actions:
For RO-WQS:
❑ Return a Completed Form NDSRR. ❑ Attach Attachment B for Certification by the NDPU.
ssue an Attachment:B�Certificaton from the ROX*.
For CO-GWS:
❑ Return a Memorandum with Permit Condition Recommendations.
When you receive this request form, please write your name and dates in the spaces below, make a copy
of this sheet, and return it to the appropriate Non -Discharge Permitting Unit contact person listed above.
RO-WQS Reviewer: Date:
CO-GWS Reviewer: Date:
FORM: NDARR 09/02 Page 1 of 1

10/10/02
Permit Number WQ0019960 Permit Tracking S3
Program Category Status Project Type
Non -discharge In review Major modification
Permit Type Version Permit Classification
Land Application of Residual Solids (503) Individual
Primary Reviewer Permit Contact Affiliation
shannon.thornburg J. Boyette
Permitted Flow Post Office Drawer 700
Marion NC 28752
Facility
Facility Name
City of Marion Residuals Land
gram
Post Office Drawer 700
Marion NC 28752
Owner
i
Owner Name
City of Marion
�t copy,
Dates/Events
Draft Scheduled Public
Orig Issue App Received Initiated Issuance Notice
07/20/01 09/26/02
Wastewater treatment and disposal
e-
Out fall P
waternoay iva
Major/Minor Region
Minor Asheville
County
McDowell
Facility Contact Affiliation
Owner Type
Government - Municipal
Owner Affiliation
J. Boyette
Post Office Drawer 700
Marion NC 28752
Issue Effective Expiration
Requested/Received Events
RO staff report received
RO staff report requested
Additional information requested
Additional information received
Groundwater comments requested
Groundwater comments received
CITY OF MARION IuJaVENDOR 00 l - y� o
VEl:DOR iCONTRO: NO. DATE :! ECEC N
WATER AND SEWER FUND i—�
P.O. sox 536 577 ; 149's2 j O8/20/20021
MARION. N.C. 28752 ; ; 014 9 3 2
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PAY **EXACTLY**205 DOLLARS AND NO CENTS**** S205.00
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TO NC. BIRO 6L NAT RESOURCE RF &D 'L
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ORDER DIVISION OF WATER QUALITY "-�- �
DE 1617 MAIL SERVICE CENTER r.wco�.tyv
Na1;,RsB.9ALEIGH NC 27699-1617
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11'D349321�' I:D53000i961: DDOi21 0721�'

OF WA9 Michael F. Easley, Governor
lot �� William G. Ross Jr., Secretary
co f North Carolina Department of Environment and Natural Resources
-i Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
April 24, 2002
MR. J. ROBERTBOYETTE, CITY MANAGER
CITY OF MARION
POST OFFICE DRAWER 700
MARION, NORTH CAROLINA 28752
Subject: Permit No. WQ0019960
City of Marion
City of Marion Residuals Land Application Program
Land Application of Residual Solids (503)
McDowell County
Dear Mr. Boyette:
In accordance with a minor modification request from Mr. Larry Carver, Wastewater Treatment
Plant Supervisor for the City of Marion that was received by the Division of Water Quality (Division) on
February 26, 2002, we are forwarding herewith a modified Permit No. WQ0019960, dated April 24,
2002, to the City of Marion for the subject residuals land application program.
This permit shall be effective from.the date of issuance until June 30, 2006; shall void Permit No.
WQ0019960, issued on July 20, 2001; and shall be subject to the conditions and limitations as specified
therein. Make note of this permit's expiration date and the fact that a permit renewal application is due to
the Division no later than six months prior to that date (i.e., see Condition VI. 7.), as the Division does not
send reminders to apply for permit renewal.
-This permit is being issued to include the continued and optional operation of facilities existing at
the Corpening Creek WWTP to lime stabilize residuals. These facilities are capable of producing a Class
A residuals product, which is currently approved for marketing and distribution by the City of Marion -
under Permit No. WQ0008681. The City of Marion has decided to rescind Permit No. WQ0008681 (i.e.,
rescission process started on February 26, 2002) now that Class B land application has been approved by
the Division. However, it was desired to allow for continued operation of the lime stabilization facilities
on an as -needed basis should the required pathogen and vector attraction reduction requirement not be
met through aerobic digestion alone. Note that all residuals, even if they are lime stabilized and/or meet
Class A standards, must be land applied in strict accordance with the conditions contained in this permit.
No marketing and distribution shall be allowed once Permit No. WQ0008681 is rescinded by the
Division.
With this minor modification, the Division has taken the opportunity to reissue this permit in the
format currently being used for all residuals land application programs. This format was developed to
facilitate new application review procedures that have been put into place by the Division. Although no
substantive changes have been made to the conditions contained within this permit, the Permittee should
take the time to reNiew this document to ensure complete familiarity and understanding of the format and
the condition language. Pay particular attention to the monitoring requirements in this permit. Failure to
establish an adequate system for collecting and maintaining the required operational information will
result in future compliance problems..
Non -Discharge Permitting Unit
1617 Mal Service Center, ,Raleigh, NC 27699-1617
DENR Customer Service Center
An Equal Opportunity Action Employer
Internet http://h2o.enrstate.nc.us/ndpu
Telephone [phone] Fax [phone]
Telephone [phone]
50% recycied/100% post -consumer paper

If any parts, requirements, and/or limitations contained in this permit are unacceptable, you have
the right to request an adjudicatory hearing upon written request within 30'days following receipt of this
permit. This request shall be in the from of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes and filed with the Office of Administrative Hearings at 6714 Mail Service
Center, Raleigh, North Carolina 27699-6714. Unless such demands are made, this permit shall be final
and binding.
If you need any additional information concerning this matter, please contact Ms. Shannon Mohr
Thornburg by telephone at [phone], extension 353, or via e-mail at
[e-mail]. %
Sinc r y,
for
Gregory J. Thorpe, Ph.D.
cc: Ms. Caroline J. Edwards, L.S.S., Earthwise Designs
McDowell Health Department
Asheville Regional Office -Water Quality Section
Asheville Regional Office -Groundwater Section
Central Office -Groundwater Section
Technical Assistance and Certification Unit
Non -Discharge Compliance/Enforcement Unit
Water Quality Central Files
NDPU Files
2

NORTH CAROLINA `
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
LAND APPLICATION OF RESIDUAL SOLIDS (503) PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
City of Marion
McDowell County
FOR THE
continued optional operation of facilities for the lime stabilization of residuals generated by the residuals
_ source -generating facilities listed in the most recently -certified Attachment A and consisting of the
_.i following minimum components: two 0.065-million gallon thickening units; two vacuum filters; a lime
storage silo; a pug mill that is provided with supplemental heat; a storage area; and all associated piping,
valves, electrical and instrumentation/control systems, and other appurtenances required to make complete
and functional facilities; and the
continued operation of a residuals land application program for the City of Marion and consisting the land
application of residuals generated by the residuals source -generating facilities listed in the most recently -
certified Attachment A to the land application sites listed in the most recently -certified Attachment B with
no discharge of wastes to surface waters, pursuant to a minor modification request from Mr. Larry Carver,
Wastewater Treatment Plant Supervisor for the City of Marion that was received on February 26, 2002,
and in conformity with the project plan, specifications, and other supporting data subsequently filed and
approved by the Department of Environment and NTaiural Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until June 30, 2006; shall void Permit No.
WQ0019960, issued on July 20, 2001; and shall be subject to the following specified conditions and
Iimitations:
I. PERFORMANCE STANDARDS
1. The residuals land application program shall be effectively maintained and operated as a non -
discharge system to prevent the discharge of any wastes resulting from the operation of this
program

2. This permit shall become voidable if the soils of the land application sites fail to assimilate the
residuals adequately and may be rescinded unless the land application sites are maintained and
operated in a manner that will protect the assigned water quality standards of the surface
waters and groundwater.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface waters or groundwater resulting from the operation of this residuals land application
program.
4. In the event that the residuals land application program is not operated satisfactorily, including
the creation of nuisance conditions, the Permittee shall cease land applying residuals to the
site, contact the Water Quality Section of the appropriate Division of Water Quality's
(Division) regional office, and take any immediate corrective actions as may be required by
the Division.
5. No residuals other than those generated by the residuals source -generating facilities listed in
the most recently -certified Attachment A of this permit shall be approved for land application
in accordance with this permit.
The pollutant concentrations in any residuals that are land applied to any land application site
shall not exceed the following Ceiling Concentrations (i.e., dry weight basis):
Parameter
Ceiling Concentration
(milli rams per kilogram)
Arsenic
75
Cadmium
85
Copper
4,300
Lead
840
Mercury
57
Mol bdenum
75
Nickel
420
Selenium
100
Zinc
7,500
7. When residuals are land applied under the conditions of this permit, the Class A pathogen
requirements and site restrictions in 40 CFR Part 503.32(a) or the Class B pathogen
requirements and site restrictions in 40 CFR Part 503.32(b), and one of vector attraction
reduction requirements in 40 CFR Part 503.33 shall be met. Additionally, an evaluation shall
be performed that demonstrates the residuals' ability to comply with this requirement. Upon
request, a copy of this evaluation, including all test results and calculations, shall be submitted.
Only residuals that are generated by the residuals source -generating facilities that are
identified as being exempt from this condition in the most recently -certified Attachment A
shall not be required to comply with the specified pathogen reduction and vector attraction
reduction requirements.
8. Only the land application sites listed in the most recently -certified Attachment B of this permit
are approved for residuals land application.
`A

9. This permit shall become voidable unless the agreements between the-Permittee and the
landowners and lessees or operators of any land application sites listed in the most recently -
certified Attachment B of this permit not owned by the Permittee are in full force and effect.
These agreements shall be considered expired concurrent with the expiration date of the permit
and shall be renewed at the same time the permit is renewed.
10. The appropriate local governmental official (i.e., county manager, city manager, etc.) shall be
notified at least 24 hours prior to the initial residuals land application event to any new land
application site. In addition, the appropriate county manager's office shall be notified prior to
the initial residuals land application event on any new site so that they will be aware that
residuals land application activities have commenced on the site.
11. The Water Quality Section of the appropriate Division's regional office shall be notified at
least 24 hours prior to the initial residuals land application event on any new land application
site. Such notification to the Regional Water Quality Supervisor shall be made during normal
office hours (i.e., from 8:00 a.n-L until 5:00 p.m.) between Monday and Friday, but excluding
State Holidays. A list of the Division's regional offices, their county coverage, and their
contact information may be downloaded from the web site at hnp://h2o.enr.state.nc.us/ndpu/.
II. OPERATION AND MAINTENANCE REOUIREMENTS
1. The facilities and land application sites shall be properly maintained and operated at all times. -
2. Upon classification of the residuals land application program by the Water Pollution Control
System Operators Certification- Commission (WPCSOCC), the Permittee shall designate a
certified land appIication/residuals operator to be in responsible charge (ORC) of the program.
The operator shall hold a certificate of the type classification assigned to the program by the
WPCSOCC. The Permittee shall also designate a certified back-up operator of the appropriate
type to comply with the conditions of 15A NCAC 8G .0202.
3. No residuals shall be stored at any land application site at any time, unless written approval
has first been requested and obtained from the Division.
4. A copy of this permit shall be maintained in all manned equipment at the land application sites
when residuals are being land applied during the life of this permit. A spill prevention and
control plan shall be maintained in all residuals transport and application vehicles.
5. When Iand applying residuals to any land application site, the following buffer zones shall be
maintained at all times:
a. 400 feet from residences or places of public assembly under separate ownership for
surface application methods; however, the buffer zone requirement may be reduced to a
m;mmum of 100 feet upon written consent of the owner and approval from the Water
Quality Section of the appropriate Division's regional office in Attachment B of this
pest;
b. 200 feet from residences or places of public assembly under separate ownership for
subsurface application methods; however, the buffer zone requirement may be reduced to
a minimum of 100 feet upon written consent of the owner and approval from the Water
Quality Section of the appropriate Division's regional office in Attachment B of this
permit;

c. 100 feet from any public or private water supply source, waters classified as SA or SB,
and any Class I or Class II impounded reservoir used as a source of drinking water for
both methods;
d. 100 feet from any streams classified as WS or B, any other stream, canal, marsh or coastal
waters and any other lake or impoundment for surface application;
e. 50 feet from any streams classified as WS or B, any other stream, canal, marsh or coastal
waters and any other lake or impoundment for subsurface application;
f. 50 feet from property lines for both surface and subsurface application methods;
g. 50 feet from public right of ways for both surface and subsurface application methods;
h. 10 feet from upslope interceptor drains and surface water diversions for both surface and
subsurface application methods; and
i. 25 feet from downslope interceptor drains, surface water diversions, groundwater drainage
systems, and surface drainage ditches for both surface and subsurface application methods.
Some of the buffers specified above may not have been included in previous permits for this
residuals land application program However, any land application sites that are listed in the
most recently -certified Attachment B of this permit, but were approved with different buffers
shall be reflagged to comply with these buffers.
6. Maximum slope for land application of residuals shall be 10 percent for surface application
methods and 18 percent for subsurface application methods.
7. Specific residuals land application area boundaries shall be clearly marked on each land
application site prior to and during a residuals land application event.
8. The metal loading rates on- any land application site shall not exceed the following
Cumulative Pollutant Loading Rates (CPLRs):
Parameter
CPLR
(kilograms per hectare)
CPLR
founds per acre)
Arsenic
41
36
Cadmium
39
34
Copper
1,500
1,338 -
Lead
300
267
Mercury
17
15
Molybdenum
n/a
n/a
Nickel
420
374
Selenium
100
89
Zinc
2,800
2,498
9. An acceptable pH shall be maintained in the soil, residuals, and lime mixture, greater than 6.0,
on all land application sites onto which residuals are Iand applied to ensure optimum yield for
the crops specified in Condition IL 13. The agronomist shall provide information on the pH
best suited for the specified crop and the soil type.
4

10. Should any of the residuals generated by the residuals source -generating facilities listed in the
most recently -certified Attachment A of this permit contain_ a high salt content (i.e., high
sodium adsorption ratio (SAR) of five or higher), the exchangeable sodium percentage (ESP)
or other method as approved by the Division, using the results from the annual soils analysis
as required by this permit, shall be monitored on all of the land application sites. The local
Cooperative Extension Office, the Department of Agriculture and Consumer Services, the
Natural Resource Conservation Service, a North Carolina -licensed Soil Scientist, or other
agronomist shall review the results and make recommendations regarding soil amendments
(e.g., gypsum, etc.) or other ameliorative mechanism for maintaining the integrity of the site in
terms of suitability for land application of residuals and maintaining conditions conducive to
crop growth. The Permittee shall implement such recommendations accordingly and shall
maintain written records of each monitoring event that includes details of the sites covered and
rate of soil amendment application.
1.1. Prior to land applying residuals to any land application site that has previously received or is
intended to receive animal waste (e.g., poultry litter, etc.) or other source of nutrients (e.g.,
fertilizer, etc.) in the future, the Permittee shall obtain information pertaining to the volume
and analysis of the applied waste/nutrients from the landowner and/or lessee/operator of the
site. The Permittee shall be responsible for verifying the volume of residuals that may be land
applied to the site such that the plant available nitrogen (PAN) loading rate for the specified
crop (i.e., see Condition H. 13.) shall not be exceeded by all of the sources of PAN applied.
Should the maximum PAN loading rate be met or exceeded, then no additional residuals shall
be land applied to the site.
12. A suitable vegetative cover, as listed in Condition H. 13., shall be maintained on land
application sites onto which residuals are land applied in accordance with the crop
management plan outlined by the local Cooperative Extension Office, the Department of
Agriculture and Consumer Services, the Natural Resource Conservation Service, or other
agronomist and as approved by the Division.
5

13. Residuals and other sources of PAN shall be land applied .to all land application sites at
agronomic rates in accordance . with the crop management plan outlined by the local
Cooperative Extension Office, the North Carolina Department of.Agriculture and Consumer
Services, the Natural Resource Conservation Service, or other agronomist. Under no
circumstances shall the following PAN loading rates land applied to any site exceed the
following for the specified crops:
PAN
PAN
Crop
(pounds per
Crop
(pounds per
acre.per year)
acre per year)
Alfalfa
200
Forest
75
(Hardwood or Softwood)
Bermuda Grass
220
Milo
100
(Hay or Pasture)
Blue Grass
120
Small Grain
100
(Wheat, Barley, or Oats)
Corn
160
Sorghum or Sudex.
180
(fin)
(Pasture)
Corn
200
Sorghum or Sudex.
220
(Silage)
(Silage)
Cotton
70
Soybeans
200
Fescue
250
Timothy, Orchard, or
200
Rye Grasses
The Permittee shall apply for and receive a modification of this permit before land applying
residuals on any land application site that -is to be established in a crop other than those listed
above. A maximum PAN loading rate for the desired crop shall be approved with the permit
modification.
If the land application sites are to be overseeded (e.g., bermuda grass in the summer and rye
grass in the winter with BOTH crops to receive residuals), then the second crop shall receive
an application of PAN'at a rate of no greater than 50 pounds per acre per year. This practice
shall be allowed as long as the second crop is to be harvested. If the -second crop is to be
planted for erosion control only and is to be tilled into the soil, then no residuals shall be land
applied to these sites because the PAN will essentially be returned to the soil.
Residuals shall not be land applied at rates greater than agronomic rates, unless authorized by
the Division.
14. Animals shall not be grazed on any land application site for 30 days after any residuals land
application event. Sites that are to be used for grazing shall have fencing that will be used to
prevent access after each event.
15. Food crops, feed crops, and fiber crops that do not come in contact with the residuals shall not
be harvested for 30 days after any residuals land application event.
16. Food crops with harvested parts that touch the residual/soil mixture and are totally above the
land surface (e.g.,- tobacco, melons, cucumbers, squash, etc.) shall not beharvested for 14
months after any residuals land application event.
0

17. Food crops with harvested parts below the surface of the land (i.e., root crops such as potatoes,
carrots, radishes, etc.) shall not be harvested for 20 months after any residuals land application
event when the residuals remain on the land surface for four months or longer prior to
incorporation into the soil.
18. Food crops with harvested parts below the surface of the land shall not be harvested for 38
months after any residuals land application event when the residuals remain on the land
surface for less than four months prior to incorporation into the soil.
19. Turf shall not be harvested for one year after any residuals land application event.
20.. Adequate provisions shall be taken to prevent wind erosion and surface runoff from conveying
residuals from the land application sites onto adjacent properties or into any surface waters.
21. Adequate procedures shall be provided to prevent surface runoff from carrying any land
applied or stored residuals into any surface waters.
22. Surface -applied residuals shall be plowed or disced within 24 hours after land application on
land application sites with no cover crop established.
23. For land application sites that are prone to flooding or within the 100-year flood elevation,
residuals shall be land applied only during periods of dry weather. The residuals shall be
incorporated into the soil within 24 hours after land application.
24. Residuals shall not be land applied during inclement weather or until 24 hours following a
rainfall event of 0.5-inch or greater in 24 hours. Any emergency residuals land application
measures shall first be approved in writing by the Division.
25. Residuals shall not be land applied to any land application site that is flooded, frozen, or
snow-covered
26. Appropriate measures shall be taken to control public access to the land application sites
during active site use and for the 12-month period following the last residuals land application
event Such controls may include the posting of signs indicating the activities being
conducted at each site.
III. MONITORING AND REPORTING REQUIREMENTS
1. Any monitoring (i.e., including groundwater, surface water, residuals, soil, or plant tissue
analyses) deemed necessary by the Division to ensure protection of the environment shall be
established, and an acceptable sampling and reporting schedule shall be followed.
7

2. Residuals generated by each residuals source -generating facility listed in the most -recently -
certified Attachment A of this permit shall be analyzed to demonstrate that they are non-
hazardous under the Resource Conservation and Recovery Act (RCRA). A corrosivity,
ignitability, and reactivity analysis as well as a Toxicity Characteristics Leaching Procedure
(TCLP) analysis shall be conducted on residuals generated by each residuals source -
generating facility listed in the most recently -certified Attachment A of this permit. The
analyses shall be performed at the frequency specified in the most recently -certified
Attachment A of this permit, and the results shall be maintained on file by the Permittee for a
minimum of five years. If residuals generated by a particular residuals source -generating
facility are land applied at a frequency less than that which is specified in the most recently -
certified Attachment A of this permit, the analyses shall be required'for each residuals land
application event. Only. residuals that are generated by the residuals source -generating
facilities that are identified as being exempt from this condition in the most recently -certified
Attachment A of this permit shall not be required to comply with this monitoring requirement.
The TCLP analysis shall include the following parameters (i.e., note the regulatory level in
milligrams per liter in parentheses):
Arsenic (5.0)
Barium (100.0)
Benzene (0.5)
Cadmium (1.0)
Carbon tetrachloride (0.5)
Chlordane (0.03)
Chlorobenzene (100.0)
Chloroform (6.0)
Chromium (5.0)
m-Cresol (200.0)
o-Cresol (200.0)
p-Cresol (200.0)
Cresol (200.0)-
214-D (10.0)
1,4-Dichlorobenzene (7.5) Nitrobenzene (2.0)
1,2-Dichloroethane (0.5)
Pentachlorophenol (100.0)
1,1-Dichloroethylene (0.7)
Pyridine (5.0)
2,4-Dinitrotoluene (0.13)
Selenium (1.0)
Endrin (0.02)
Silver (5.0)
Hexachlorobenzene (0.13)
Tetrachloroethylene (0.7)
Heptachlor (and its hydroxide) (0.008)
Toxaphene (0.5)
Hexachloro-1,3-butadiene (0.5)
Trichloroethylene (0.5)
Hexachloroethane (3.0)
2,4,5-Trichlorophenol (400.0)
Lead (5.0)
2,4,6-Trichlorophenol (2.0)
Lindane (0.4)
2,4,5-TP (Silvex) (1.0)
Mercury (0.2)
Vinyl chloride (0.2)
Methoxychlor (10.0)
Methyl ethyl ketone (200.0)
After the residuals have been monitored as specified above for two years at the frequency
specified in the most recently -certified Attachment A of this permit, the Permittee may submit
a request to the Division for a permit modification to request a reduction of this monitoring
requirement. In no case, however, shall the frequency of monitoring be less than once per
permit cycle.

3. An analysis shall be conducted on residuals generated by each residuals source -generating
facility listed in the most recently -certified Attachment A of this permit. The -analysis shall be
performed at the frequency specified in the most recently -certified Attachment A of this
permit, and the results shall be maintained on file by the Permittee for a minimum of five
years. If residuals generated by a particular residuals source -generating facility are land
applied at a frequency less than that which is specified in the most recently -certified
Attachment A of this permit, an analysis shall be required for each residuals land application
event. The analysis shall include, but shall not necessarily be limited to, the following
parameters:
Aluminum
Ammonia -Nitrogen
Arsenic
Cadmium
Calcium
Copper
Lead
Magnesium
Mercury
Molybdenum
Nickel
Nitrate -Nitrite Nitrogen
Percent Total Solids
pH
Phosphorus
Potassium
Selenium
Sodium
Total Kjeldahl Nitrogen
Zinc
Plant Available Nitrogen
(by calculation)
After the residuals generated by a particular residuals source -generating facility have been
monitored for two years at the frequency specified in the most recently -certified Attachment A
of this permit, the Permittee may submit a request to the Division for a permit modification to
reduce the frequency of this monitoring requirement. In no case, however, shall the frequency
of this. monitoring be less than once per year when a residuals land application event of
residuals generated by the residuals source -generating facility occurs during that year.
4. Residuals generated by each residuals source -generating facility listed in the most recently -
certified Attachment A of this permit shall be monitored for compliance with Condition I. 7.
The monitoring shall be performed at the frequency specified in the most recently -certified
Attachment A of this permit,. and data to verify pathogen and vector attraction reduction of the
residuals shall be maintained. on ..file _by ..the Permittee. for - a..minimum of five years. The
required data shall be specific to the stabilization process utilized, but also shall be sufficient
to demonstrate clear compliance with the Class A pathogen reduction requirements in 40 CFR
Part 503.32(a) or the Class B pathogen reduction requirements and site restrictions in 40 CFR
Part .503.32(b) as well as one of vector attraction reduction requirements in 40 CFR Part
503.33. In addition, the Environmental Protection Agency (EPA) certification statements
concerning compliance with pathogen reduction requirements, vector attraction reduction
requirements, and management practices shall be completed quarterly by the proper authority
or authorities, if more than one is involved (i.e., either the person who prepares the residuals,
the person who derives the material, or the person who applies the residuals). Only residuals
that are generated by the residuals source generating facilities that are identified as being
I.
exempt from Condition 7. in the most recently -certified Attachment A of this permit shall
not be required to comply with this monitoring requirement.
5. Laboratory analyses as required by Condition M. 2., Condition III. 3., and Condition III. 4.
shall be performed/gathered on the residuals as they are to beland applied. Furthermore,
analytical determinations made pursuant to the monitoring and reporting requirements of this
permit shall bemade by a laboratory certified by the Division for the required parameter(s)
under 15A NCAC 2H .0800 or 15A NCAC 2H .1100.
9

6. Proper records shall be maintained by the Permittee tracking all residuals land application
events. These records shall include, but are not necessarily limited to, the following
information:
a. Source of residuals;
b. Date of land application;
c. Location of land application (i.e., site, field, or zone number);
d. Method of land application;
e. Weather conditions (i.e., sunny, cloudy, raining, etc.);
f. Soil conditions (i.e., dry, wet, frozen, etc.);
g. Type of crop or crops to be grown on field;
h. Volume of residuals land applied in gallons per acre, dry tons per acre, or kilograms per
hectare;.
i. Volume of animal waste or other nutrient source applied in gallons per acre, dry ton per
acre, or kilograms per hectare (if applicable);
j. Volume of soil amendments (i.e., lime, gypsum, etc.) applied in gallons per acre, dry ton
per acre, or kilograms per hectare (if applicable); and
i. Annual and cumulative totals of dry tons per acre of residuals as well as animal waste and
other source of nutrients residuals (i.e., if applicable), annual and cumulative pounds per
acre of each heavy metal (i.e., shall include, but shall not be limited to, arsenic, copper,
lead, mercury, molybdenum, nickel, selenium, and zinc), annual pounds per acre of PAN,
and annual pounds per acre of phosphorus applied to each field.
7. A representative annual soils analysis (i.e., Standard Soil Fertility Analysis) shall be
conducted on each land application site on which a residuals land application event in the
respective calendar -year has occurred or -is to -occur, and the results shall be maintained on file
by the Permittee for a minimum of five years. The Standard Soil Fertility Analysis shall
include, but is not necessarily limited to, the following parameters:
Acidity Exchangeable Sodium Percentage (by calculation)
Calcium Magnesium Phosphorus
Cation Exchange Capacity Manganese Potassium
Copper Percent Humic Matter Sodium
Base Saturation (by calculation) pH Zinc
8. Three copies of all required monitoring and reporting requirements as specified in Condition
III. 1., Condition III. 2., Condition III. 3., Condition 111. 4., Condition III, 5., Condition III, 6.,
and Condition III. 7. shall be submitted annually on or before March 1st of the year following
the residuals land application event to the following address:
NCDENR-DWQ
Water Quality Section
Non -Discharge Compliance/Enforcement Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
10

9. Noncompliance Notification:
The Permittee shall report by telephone to the Water Quality Section of the Division's
Asheville Regional Office at telephone number [phone], as soon as possible, but in no
case more than 24 hours or on the next working day following the occurrence or first
knowledge of the occurrence of any of the following:,
a. Any occurrence with the residuals land application program that results in the land
application of significant amounts of residuals that are abnormal in quantity or
characteristic.
b. Any failure of the residuals land application program resulting in a release of material to
receiving waters.
c. Any time that self -monitoring information indicates that the residuals land application
program has gone out of compliance with the conditions and limitations of this permit or
the parameters on which the program system was designed.
d. Any process unit failure, due to known or unknown reasons, that render the residuals land
application program incapable of adequate residuals treatment.
e. Any spillage or discharge from a vehicle or piping system transporting residuals to the
application site.
Persons reporting such occurrences by telephone shall also file a written report in letter form
within five days following first knowledge of the occurrence. This report shall outline the
actions taken or proposed to be taken to ensure that the problem does not recur.
IV. GROUNDWATER REQUIREMENTS
1. Land Application Site Requirements:
a. Each land application site identified with a GW A in the most recently -certified
Attachment B of this permit is dominated by soils with a mean seasonal high water table
greater than three feet below the land surface. Residuals land application events may
occur on these sites throughout the year.
b. Each Iand application site identified with a GW-B in the most recently -certified
Attachment B of this permit is dominated by soils with a meanseasonal high water table
between one and three feet below the land surface. Residual land application events on
these sites shall be prohibited from December through March, inclusive. No residuals
shall be land applied to these sites when the vertical separation between the depth. of
residuals land application and the water table is less than three feet. The actual water
table depth for seasonally -restricted soils shall be verified by soil borings within 24 hours
prior to any residuals land application event that occurs from April through November,
inclusive. The number of borings advanced shall be sufficient to characterize water table
conditions across the land application site adequately. Any open borings shall be properly
filled with native soil, prior to the residuals land application event,.to decrease the chance
of any residuals contaminating the groundwater.
11

2. Applicable Boundary Requirements:
a. The COMPLIANCE BOUNDARY for residuals land application programs is specified by
regulations in 15A NCAC 2L (i.e., "Groundwater Classifications and Standards"). The
Compliance Boundary for each land application site is established at either 250 feet from
the residuals land application area or 50 feet within the property boundary, whichever is
closest to the residuals land application area. An exceedance of Groundwater Quality
Standards at or beyond the Compliance Boundary is subject to immediate remediation
action according to 15A NCAC 2L .0106 (d)(2).
b. The REVIEW BOUNDARY shall be established around each land application site
midway between the Compliance Boundary and the perimeter of the residuals land
application area. Any exceedance of Groundwater Quality Standards at the Review
Boundary shall require action in accordance with 15A NCAC 2L .0106 (d)(2).
3. Additional Requirements:
a. Any groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
V. INSPECTIONS
1. Prior to each residuals land application event, the Permittee or his designee shall inspect the
residuals storage, transport, and application facilities to prevent malfunctions and
deterioration, operator errors, and discharges that may cause or lead to the release of wastes to
the environment, a threat to human health, or a nuisance. The Permittee shallmaintain an
inspection log or summary including at least the date and time of inspection, observations
made, and any maintenance, repairs, or corrective actions taken by the Permittee. This log of
inspections shall be maintained by the Permittee for a period of five years from the date of the
inspection and shall be made available to the Division or other permitting authority, upon
request.
2. Any duly authorized officer, employee, or representative of the Division may, upon
presentation of credentials, enter and inspect any property, premises, or place on or related to
the land application sites or facilities at any reasonable time for the purpose of determining
compliance with this permit; may inspect or copy any records that must be' kept under the
terms and conditions of this permit; and may obtain samples of groundwater, surface water, or
leachate.
VI. GENERAL CONDITIONS
I. This permit shall become voidable unless the residuals land application events are carried out
in accordance with the conditions of this permit, the supporting materials, and in the manner
approved by the Division.
2. This permit shall be effective only -with respect to the nature and volume of residuals described
in the application and other supporting data.
3. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division in accordance with North Carolina General
Statutes § 143-215.6A through § 143-215.6C.
12

4. The annual administering and compliance fee shall be paid by the Permittee within 30 days
after being billed by the Division. Failure to pay the fee accordingly may cause the Division
to initiate action to revoke this permit, as specified by 15 NCAC 2H .0205 (c)(4).
5. The issuance of this permit does not preclude the Permittee from complying with any and all
statutes, rules, regulations, or ordinances that may be imposed by other government agencies
(i.e., local, state, and federal) which have jurisdiction, including, but not limited to, applicable
river buffer rules in 15A NCAC 2B .0200, soil erosion and sedimentation control requirements
in 15A NCAC Chapter 4 and under the Division's General Permit NCGO10000, and any
requirements pertaining to wetlands under 15A NCAC 2B .0200 and 15A NCAC .0500.
6. This permit may be modified, revoked, and/or reissued to incorporate any conditions,
limitations and monitoring requirements the Division deems necessary in order to protect the
environment and public health adequately.
7. The Permittee, at least six months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Division shall review the adequacy of the facilities
and residuals land application program described therein, and if warranted, shall extend the
permit for such period of time and under such conditions and limitations as it may deem
appropriate.
8. This permit shall not be automatically transferable. In the event that there is a desire for the
residuals land application program to change ownership or to change the name of the
Permittee, a formal permit request shall be submitted to the Division documentation from the
parties involved and other supporting materials as may be appropriate. The•approval of this
request shall be considered on its merits and may or may not be approved.
Permit issued this th�,X"enty-fourth day of April, 2002.
NORTH L1NA NAMNTAL MANAGEMENT COMMISSION-
.
for Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0019960
13

MACUMCNT A Approved Residual Source-GenciratInp Fucilitles
Permit No. WQ0019960
City of Marion
City of Marion Residuals !wend Application Program
Owner
Facility Name
County
Permit Number
Issued By
Is 5037
Maximum
Monitoring
Moultor•Ing
Approved
Ury'rons
Frequency rur
Frequency for
Mineralization
Per Year
Condition III. 2.
Condition III. 3. and
Bate
Condition I11.4.
City or Marlon
Carpening Creek WW'1'I'
McDowell
NC0031879
DWQ
503
290.00
Annually
Annually
0.30
TOW
290.00
Permit No. M" . ' '• 160 i
Pugc. i Certification Untc: t• 2002

ATI'ACIIMEN'I' II - Approved Land Application Sites
Per"Iit No. WQ0006119
Town of Crivin
Town of Erwin Residuals 1-mid Application Program
Slle/Field Ill
Landowner
Lessee/Operator
County
Latitude
Longitude
Net Acreage
Applicable
Restriction in
Condition IV. 1.
C1°
K1b
K2"
R1
Total For County
Total
Causb , Curtis
Khan , Toun &Tung
Khan , Toua & Ton g
Ross, Wayne
McDowell
McDowell
McDowell
McDowell
McDowell
9.50
I6.00
38.00
16.00
79.50
79.50
GW-A
GW-A
G W-A
GW-A
a A reduced buffer from a residence under separate ownership has been approved for this land application site. Residuals may be land applied to within 100 feet of the residence
owned by John Kirby (i.e., indicated by the label !'DI" on the approved buffer map), regardless of whether a surface or a subsurface application method is used.
t, Reduced buffers from residences under separate ownership has been approved for this land application site. Residuals may be land applied to within 100 feet of the residences
owned by Ruby Kelley (i.e., indicated by [lie labels "DV and "D2" on the approved buffer snap) and to within 200 feet of the residences owned by Sy Thau (i.e., indicated by the
labels "D3" and "D4" on the approved buffer maps), regardless of whetlier if surface or a subsurface application method is used.
This land application site was previously an apple orchard that has since been converted to pasture land. The Division's Groundwater Section has expressed concern regarding
the historical pesticide application practices at the site and the fact that these could have adversely impact soil and groundwater quality. Although it is not a requirement
of this permit, it is strongly advised that the Pcrmittee receive a "hold harmless" agreement with respect to prior contamination before land applying residuals to this site.
a Reduced buffers from residences under separate ownership has been approved for this land application site. Residuals may be land applied to within 200 feel of the residences
owned by Chia Kee Yang (i.e., indicated by the labels "D5" and "DG" on the approved buffer map) and to within 200 feet of the tesidence owned by Kenneth D. VanBuskirk
(i.e., indicated by life label "D7" on the approved buffer maps), regardless of whether a surface or a subsurface application method is used.
Permit No. WQ0019960 page I of 1 Certification Date: April 24, 2002

F. _aSiey. Gnvemn
William G. Ross Jr., Secre;a.Y
Non. Carolina Department of Environment and Natural Resources -
Alan W. Klimek, P.E.. Director
Division of Water Quality
August 2. 2002
'\IR. I. POBEP. T BO`,'ETTE. CITY MANAGER,
CI T 1' Or '%4AR10N
POST OYr10E Box 700
1Ni.4P.ION. NORTH CAROLINA 2875 )
Subject: Permit No. WQ0019960
Return of Permit Application Package
City of Marion
City of Marion Residuals Land Application Program
Land Application of Residual Solids (503)
McDowell County
Dear NIr. Bovette:
This letter is in referenced to the permit application package received on July 11, 2002 for the
modification of the above -referenced residuals land application program.. The Division of Water
Quality's (Division) Non -Discharge Permitting Unit has completed an administrative review of the
package and is returning the enclosed permit application package due to the following reasons:
Form NDRLAP:
1. Item I. 8. on Page 2 of 5 states that no fee is required because adding land application sites to
a residuals land application program is a minor modification. Note that this statement is in
error. Adding sites to a program constitutes a major modification and, therefore, a major
modification fee is required to process the application. Because the City of Marion Residuals
Land Application Program is a minor non -discharge program, the correct major modification
fee is S205. Please subinut this fee accordingly.
2. Item II. 3. on Page 3 of 5 indicates that the net acreage associated with land application sites
currently certified for this residuals land application program is to increase as part of the
requested permitting action. From the Form LASCA submitted with this permit modification
application package. it appears as if several additional sites not currently certified for this
program are requested to be certified. Therefore. it appears as if the requested modification is
for the addition of sites (i.e.. rather than art increase in net acreage). Please submit a revised
Page 3 of > accordingly.
_ . The tables in Item III. 3. on Page 4 of 5 must be completed in its entirety, regardless of
whether or not residuals are to be surface applied or incorporated/injected to the land
application sites. In addition, note that "0," "n/a," or lines through cells should not be used at
all in completing this application form. Please submit a revised Page 4 of 5 accordingly.
Non -Discharge Permitting Unit
1517 Mail Service Center, Raleigh, NC 27699-1617
DENR Customer Service Center
An Equal Opportunity Action Employer
ZXX
�,lC
Internet httpJln2o.enr.state.nc.us/ndpu
Telephone [phone] Fax [phone]
Telephone [phone]
50% recycled/10% post -consumer paper

Form LASCA•
1. Item H. 3. on Page 2 of 2 indicates that the net acreage associated with land application sites
currently certified for this residuals land application program is to increase as part of the
requested permitting action. It appears as if several additional sites not currently certified for
this program are requested to be certified only. Therefore, it appears as if the requested
modification is for the addition of sites only (i.e., rather than an increase in net acreage of
currently certified sites). Please submit a revised Page 2 of 2 accordingly.
2. Please note, for future reference, that the following order should be used when attaching
required supplemental documentation to Form LASCA for each land application site:
i By Ladd Application Site:
■ Attachment Order 3-c: Landowner Agreement Attachment (Form LOAA).
• Attachment Order 3-d: Buffer Waiver Agreement Attachment (Form BWAA).
• Attachment Order 3-e: An updated vicinity/buffer map that meets all of the criteria in
the latest version of the document entitled "Guidance for the Preparation of
Vicinity/Buffer Maps for North Carolina Residuals Permitting Programs."
• Attachment Order 3-f: A soils and agronomic evaluation that meets all of the criteria
in the latest version of the document entitled "Guidance for. the Preparation of Soils
and Agronomic Evaluations for North Carolina Residuals Permitting Programs."
Be aware that the Division wants all supplemental documentation that relates to a particular
land application site to be included together in the permit application package in the order
specified above.
For the above -listed reasons, the Division must return your permit application package as
incomplete in accordance with North Carolina General Statute § 143-215.1. Please be advised that
operation, alteration, expand, and/or change of any residuals management program without a valid permit
is a violation of North Carolina General Statute § 143-215.1 any may subject the owner/operator of the
program to enforcement action in accordance with North Carolina General Statute § 143-215.6. "Civil
penalties of up to S25,000 per day per violation may be assessed for failure to secure a permit required by
North Carolina General Statute § 143-215.1.
When you have obtained the information that is needed to make your permit application package
complete, you may resubmit the package for review and approval. Note that the Division has returned
the entire permit application package to your consultant; therefore, the returned package along
with the above -listed omitted items must be resubmitted to the mailing address listed on the first
page of this correspondence if you choose to continue pursuing a modified permit for this residuals
management program. If you have any questions an/or comments regarding this matter, please do not
hesitate to contact me at any time at [phone], extension 353, or at [e-mail],
and I will be happy to provide additional explanation as required.
2

Thank you in advance for your cooperation and assistance.
Sin rely, —1
,�
Shannon Mohr Thornburg/ L
Environmental Engineer
Non -Discharge Permitting Unit
cc: Ms. Caroline J. Edwards, L.S.S., Earthwise Designs (w/ enclosures)
Mr. Larry Frost, Asheville Regional Office - Water Quality Section
Asheville Regional Office - Groundwater Section
Central Office - Groundwater Section
Permit File WQ0019960
NDPU Files - Returned Projects 2002 (Pre -Review)
3

EARTHWISE DESIGNS
724 Duncan Road Rutherfordton, NC 28139
ph.828)247-0067 [e-mail]
Sept. 16, 2002
To: Shannon Thornburg, Non Discharge Compliance Unit
Division of Water Quality, NCDENR
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Return of Permit Appl. Package dated Aug. 2, 2002
Permit Modification to Add Acreage
PERMIT # WQ0019960
City of Marion
Dear Ms. Thornburg:
Enclosed please find the requested information re your letter dated Aug. 2; in four (4) copies;
and a check for $205.00.
I updated the biosolids analysis with Year 2002 sample data; the PAN rates are very low due to
the addition to the waste stream of a natural decomposition accelerant product in use since last
fall.
Earthwise Designs appreciates your response to Larry Frost at your most earliest convenience.
cerely yours,
Caroline J. Edw s
Lic. Soil Scientist
WATER REC[=IVEnD —
_ QUALITY SCCTIOnI
SEP 2 5.I;r�
NON-DISCHAIRCE PERr�ii'Ti IiVG

mailbox: ///Macintosh%2^L")/Documents/Mozilla/Profiles/carotin%...
Fr: Shannon Thornburg
Re: Permit package re Marion #WQ0019960
With regard to Item 1 of Form NDRLAP: a check for $205 will be sent.
■1
®- P-04
Item 2. I have placed a checkmark in the 'ADD' box under Item II.3 on page 3 of 5; thus both the
'increase' and the 'add' boxes are now checked, since we are adding both new sites and new fields on
old sites. If I recall correctly, the request involved only adding new sites/fields to the program.. The
"increase" box should only be checked if an existing site/field is being increased in acreage (e.g., land
immediately adjacent to the site/field is being cleared, a well is being abandoned such that a buffer
disappears, etc.). Therefore, I believe that the "add" box should be the only box checked for this major
modification. That is, gain, if my recollection is correct.
Item 3. On page 4 of 5, Table 3. a. If incorporation or injection is not going to be used for this permit,
then why does this column need to have other than the '0' that I originally submitted? What other number
do you suggest? This is a "pretend you can't meet VAR and have to inject/incorporate" question. If the
residuals were to be subsurfacely applied, the PAN concentration would not be 0 mg/kg. Therefore, you
need to calculate the subsurface PAN concentration. of the residuals and then determine what land base is
required to land apply the total PAN generated at agronomic rates. This gives us a general feeling of how
land limited or flush the program is. And, typically, we see people using injection/incorporation when.
having VAR problems, so this is information is helpful to us in determining the adequacy of the program
as a whole.
For Table 3b. I have no comments to make regarding the sites; therefore if lines through the cells are not
to be used, then I assume leaving them empty is appropriate. However, your note that'0', n/a and lines
thro cells should not be used makes me doubt my assumption. Please inform. For 3b., "0" would be an
appropriate answer. The reason that "0" or "n/a" is not appropriate for 3a or 3c is that, if the residuals
are subsurfacely applied, there are numbers associated with the questions asked. If there is no land in
row crops or plantation forest, then "0" is an appropriate answer.
Also, I used a'0' to denote that there are no acres in the program on forestland or row crops. If a zero
should not be used, then what do you suggest be used in this column? See answers provided above. I
should have been more clear in my return letter. I was probably more referring to 3a and 3c than for 3b.
Although, if I remember correctly, there were lines through boxes in 3b, which really does not tell us
anything. It leaves us second-guessing what your intent was. A "0" means that there is, in fact, no
acreage that has these cover. crops.
For Table 3c. If incorporation or injection is not going to be used for this permit, then why does this
column need to have other than the 'line -through' that I originally submitted? What should be here? See
answers provided above.
Regarding Form LASCA:
Item 1. You reference Item II.3. on page 2 of 2. The form LASCA 02/02 that I used does not have an
Item II.3. on page 2 of 2., but rather is all Section I. Land Application Site Information, followed by the
phrase ***End of Form LASCA 02/02******"Has this form been changed or updated? Please
inform. No, this form has not been changed or updated. Who knows where my mind was?!? This was
my error ... you are correct. See my answer to Form NDRLAP Item 2 above.
1 of 2 9/19/02 3:32 PM

State of North Carolina
Department of Environment
and Natural Resources
Asheville Regional Office
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
Division of Water Quality
Mr. J. Robert Boyette
City Manager — City of Marion
Post Office Drawer 700
Marion, North Carolina 28752
Mr. Boyette:
Gt7i"'I
�f
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
WATER QUALITY SECTION
June 11, 2002
Subject: Non -Discharge Compliance Inspection
Status: Compliant
City of Marion
Residuals Land Application Program
Permit Number WQ0019960
`McDowell County
On May 31, 2002 Mr. Kevin Barnett and I conducted a Non -Discharge Compliance
Inspection of the City of Marion's Residuals Land Application Program. Mr. Larry Carver of the
City of Marion and Mr. David Key of Southern Soil Builders assisted during this inspection, their
cooperation was greatly appreciated. The purpose of this inspection was to determine the
compliance status of the Residuals Land Application Program. The program was determined to
be compliant, however there were documentation issues that should be addressed prior to the
next application. A copy of the inspection report is attached for your records.
Should you have any question regarding this inspection or other water quality issues
contact me at [phone].
Sincerely,
L ry Frost
Environmental Technician
Enclosure
xc: Non- Discharge Permitting Unit
Larry Carver
David Key
Asheville Regional Office, 59 Woodfin Place, Asheville, North Carolina 28801 Phone: [phone] Fax: [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled\110% Post Consumer Paper

tate of North Carolina
Department of Environment YIPF4
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary NCDENR
Gregory J. Thrope, Ph.D., Acting Director NcrZTH CA <o_NA DEMMM ENT OF
EwvrZ Kf,'CwJT ONC NdT.]PAL
Non -Discharge Compliance Inspection
WQ Permit Number
WQ0019960
County
McDowell
Permittee
Cuty of Marion Residuals
Application Program
Land Npdes Number(s)
>NCO071200
NCO031879
Issuance Date
4/24/2002
Expiration Date
6/30/2006
Soc Issuance Date
Soc ExpirationDate
Permittee Contact
J. Robert Boyette
Phone Permittee Contact
828.652.3551
ORC Certification #
ORC Name
Larry Carver
Phone ORC
828.652.8843
24hr Contact Name
Larry Carver
Phone 24hr
828.652.8843
Reason For Inspection (Select One)
10 Routine O Complaint O Follow -Up
O Other...
Type Of Inspection (Select One)
10 Collection System O Spray Irrigation
Og Residual
Inspection Summary
Inspector's Name
Phone Inspector
Inspection Date
828.251.6208 Fax Inspector 828.251.6452
5/31 /2002
page 1

Non Discha _ a Compliance Residua ispection
Permittee ICity of Marion Residuals Land Application
Permit Number IWQ0019960
Inspection Date 5/31/2002
Type
0 Land Application 0 Distribution and Marketing
Was a copy of current permit available?
Were current metals and nutrient analysis available? (see permit for frequency)
a. TCLP analysis?
b. SSFA ( Standard Soil Fertility Analysis)?
Were nutrient and metal loading calculated to determine most limiting parameters? YTD
Were hauling records available?
How many gallons / tons hauled during the calendar year to date?
Were field loading records available?
Were records of lime purchased available?
® Fields
❑ Pathogen and Vector Attraction Reduction (if applicable)
Were Operation and Manintance records present?
Were Operation and Manintance records Complete?
Has the land application equipment been calibrated?
Pathogen and Vector Attraction (if applicable):
1* Yes 0 No 0 N/A
OQ Yes 0 No 0 N/A
Yes O No O NIA
DQ Yes 0 No O NIA
Yes 0 No O N/A
DQ Yes 0 No 0 N1A
849,000 gallons
Yes O No O NIA
DQ Yes 0 No 0 NIA
O Yes DQ No O NIA
Q Yes DQ No 0 N/A
0 Yes 0 No 0 N/A
a. Fecal coliform SM 9221 E ( Class A or B) DQ Yes O No O NIA
0 ( Class A, all test must be <1000 MPN / dry gram )
* (Geometric mean of 7 samples per monitoring period for Class B <2.0*106 CFU / dry gram )
Fecal coliform SM 9222 D ( Class B only) 10 Yes DQ No 0 NIA
O ( Geometric mean of 7 samples per monitoring period for Class B <2.0*106 CFU / dry gram )
b. Salmonella ( Class A, all tests must be < 3MPN / 4 grams dry) JOYes O No * N/A
c. Time / Temp on: 10 Yes Q No 0 N/A
❑ Digester ( MCRT ) ❑ Compost ❑ Class A lime stabilization
d. Volatile Solids Calculations. DQ Yes 0 No O N/A
e. Bench -Top Aerobic/ Anaerobic digestion results. 10 Yes 0 No * N/A
f. pH records fo Lime Stabilization (Class A or B). 10. Yes 0 No DQ N/A
Treatment
Equipment
Additional
Equipment
® Aerobic Digestion ❑ Alkaline Stabilization (Other)
❑ Auto Thermophilic Aerobic Digestion ❑ Compost (Windrow)
❑ Anaerobic Digestion ❑ Compost (Aerated Static Pile)
❑ Drying Beds ❑ Other
❑ Alkaline Stabilization (Lime)
page 2

Non ®ischai Compliance Residual ispection
Permittee City of Marion Residuals Land Application
Permit Number IWQ0019960
Inspection Date 5/31/2002
Transport
Was a copy of the permit in transport vehicle? ❑ Yes QQ No O N/A
Was a copy of the spill control plan in vehicle? 0 Yes Q No Q N/A
Did transport vehicle appear to be maintained? QQ Yes O No N/A
Storage
❑ Lagoon ❑ AST OUST ❑ Septic Tank ❑ Drying Beds []Concrete Storage Pads
How many months storage? 1>6 months
Was a copy of the spill control plan on site? O§ Yes O No Q N/A
If Applicable:
Is lagoon lined? 10 Yes O No Q N/A
Above Ground Tank ❑ Aerated ❑ Mixed Aerated Hp: Mixed Hp:
Under Ground Tank lZ Aerated ® Mixed Aerated Hp: 140 Mixed Hp: 140
Sampling
Describe Sampling:
Was sampling adequate?
* Yes Q No O N/A
Was sampling representative?
* Yes Q No N/A
Disposal
Were buffers adequate?
QQ Yes Q No O N/A
Is the cover crop type specified in permit?
QQ Yes Q No O NIA
Were exceedence of PAN limits documented?
QQ Yes Q No Q NIA
Was the application site in good condition?
QQ Yes O No N/A
Was the site free of runoff / ponding?
*i Yes Q No NIA
Was the acreage specified in the permit being utilized?
QQ Yes Q No ❑ N/A
Was the application equipment present and operational?
QQ Yes O No ❑NIA
Were there any limiting slopes on disposal field?
(10% for surface application)
10 Yes * No N/A
(18% for subsurface application)
10 Yes Q No N/A
Are monitoring wells called for in permit?
10 Yes QQ No N/A
Was there access restrictions and / or signage?
QQ Yes O No N/A
Was a copy of the permit on site during application events?
QQ Yes Q No ❑ N!A
Was the application site free of odors or vectors?
* Yes Q No O N/A
Were nutrient / crop removal practices in place?
* Yes O No ❑NIA
page 3

CITY OF MAMON
P.O. Drawer 700 OFFICE OF THE
WASTE TREATMENT
Marion, North Carolina 28752 PLANT SUPERVISOR
To: Larry Frost.
Division of Water Quality
Environmental Technician
Asheville Regional Office
- Subject: Land Application Deficiency
Permit Number WQ0019960
City of Marion
Corpening Creek Wastewater Treatment Plant
Mr. Frost
The tests for percent solids were taken to help prior to land application to give us a
more accurate reading of the total solids to be land applied. Dennis key with southern soil
builders discussed this with Shannon Thornburg earlier in the year of 2001. Now we will
take only one reading per land application event. On the ph adjustment, the permit was
not received until the last week of July.200,1..We land applied in, the first part. of August.
Before lime could be applied, the farmer stated that the grass was too tall to allow lime
trucks to apply lime. He said he would allow us on to apply limeas soon as he felt that
conditions were suitable. This is why lime was not applied. The field summery form for
field number R-1. and K l .the pan will be amended now that the percent solids issue is
resolved. Hydro Analytical Laboratories have already sent us a new an sheet with
the method number and mpn/gram geometric mean. The correct calculation will be will
be replaced in the report and a corrected copy will be sent to your office. I would like to
thank you for your assistance on these matters and. if you have any more questions give
me a call.
Larry Carver, WWTP Supervisor

SHYDRO ANALYTICAL LABORA'I'ORIES
6300 Ramada Drive, Box C-2
Clemmons, NC 27012
[phone]
Fax [phone]
CERTIFICATE OF ANALYSIS
May 7, 2002
CLIENT NAME
HMS MARION
CLIENT NUMBER
SAMPLE NUMBER
80000399
210106
210107
210107
210107
210107
210107
210107
210107
COLLECTED DATE
2/12/01
2/12/01
2/12/01
2112101
2/12101
- 2/12/01
2/12/01
2/12/01
RECEIVED DATE
2/13101
2113/01
2/13/01
2/13/01
2/13/01
2/13/01
2/13/01
2/13/01
CORP CRK
CORP CRK
CORP CRK
CORP CRK
CORP CRK
CORP CRK
CORP CRK
CORP CRK
DESCRIPTION
CLASS B
CLASS B
CLASS B
CLASS B
CLASS B
CLASS B
CLASS B
CLASS B
A
B
C
D
E
F
G
TEST
UNITS
RESULTS
RESULTS
RESULTS
RESULTS
RESULTS
RESULTS
RESULTS
RESULTS
% SOLIDS
%
14.9
15.0
14.9
15.2
15.3
15.3
15.2
15.5
FECAL SLUDGE
MPN/GRAM
2667
5369
4636
11111
1307
1316
7097
pH
SU
5.13
TCLP
MG/L
ATTACHED
-
** 3672 MPN/GRAM
*** SM9221E
CERTIFICATION # NC 103
NC 37733
CERTIFIED BY:

State of North Carolina
�
Department of Environment and Natural Resourc '
l5 U V�
Division of Water Quality
WATERSHED CLASSIFICATION ATTACHMEl'.„ MAY 7 2002 ..',
FOR RESIDUALS PROGRAMS 1,
(THIS FORM MAY BE PHOTOCOPIED FOR USE AS AN ORIGINAL)
AS': t)) -.eft+n. r,: J" r•• /.;
The Division of Water Quality (Division) will not consider this attachment form to be complete
unless all the instructions are followed. Failure to follow the instructions or to submit all of the
required items will lead to additional application processing and review time.
For more information or for an electronic version of this form, visit our web site dt: http://h2o. enr.state.nc.us/ndpu/
INSTRUCTIONS TO THE APPLICANT:
A. Attachment Form:
✓ Do not submit this attachment form for review without a corresponding residuals program application,
form (Form NDRLAP).
✓ Any changes to this attachment form will result in the application package being returned.
B. Prepare the attachment form with the requested information 'for each location where the residuals
program activities are planned to occur within a particular regional office county`coverage.
✓ Additional copies of Page 2 of 2 of this attachment form may be used if necessary.
✓ Use a portion of an 8.5-inch by 11-inch copy of the portion of a 7.5-minute USGS Topographic Map to
identify the location where the residuals program activities are planned to occur as well as the closest
downslope surface waters as clearly as possible. Each map portion must be labeled with the map name and
number, the identified location, and be of clear and reproducible quality. y�
✓ Latitudes and longitudes must reported as being based on either the NAD 27 or the NAD 83 data systems. !, AJU
✓ Acceptable methods -of determining location latitudes and longitudes and their corresponding codes are as
follows:
♦
Address Matching (ADD)
♦
Digital or Raw Photo Extraction (EXT)
♦
Aerial Photography with Ground Control (AER)
♦
Geodetic Quality GPS Survey (GEO)
♦
Cadastral Survey (SUR)
♦
LORAN-C Navigation Device (LOR)
♦
Conversion from Coordinate Plane (CP)
♦
Navigation Quality GPS (GPS)
♦
Conversion from Township -Section -Range (TSR)
♦
Remote Sensing (RS)
♦
Conversion from Universal Trans Merc (UTM) '
♦
Zip Code Centroid (ZIP)
♦
Map Interpretation by Digital or Manual Extraction (MAP)
✓ Location accuracy must be provided to the nearest unit (e.g., nearest
second, tenth of a second, etc.).
C. Mail or fax the attachment form and: the map portions to the appropriate regional office for review and
to obtain the waterbody and classification information.
✓ A list of the Division's regional offices, their county coverage, and their contact information may be
downloaded from the web site at: http://h2o.enr.state.nc.us/ndpu/.
✓ The Division will not consider this attachment form to be complete until it is completed by the appropriate
regional office.
To: Regional office:
Address of re�giornal otffice: � S
City. _ S t 1 State: Zip:
Facsimile number: ( )
i Sc)r
Please provide me with the waterbody name(s), stream index number(s), and current/proposed
classification(s) of the surface waters that are closest to and downslope from the location(s) where the
proposed residuals program activities are planned to occur, as identified on the attached map segment.
Signature of regional office staff: Date: O , Z
FORM: RWSCA 02/02 Page I of 2 Attachment Order 3-a

-E-
Location.ID
County
Latitude
Longitude
Location
Datum
Location
Method
Code
Location
Accuracy
Waterbody Subbasin and
Stream Index No.
(To Be Completed by DWQ)
Current and
Proposed Class
(To Be Completed
by DWQ)
OS 1 ` 5'
I
C�
i�
C >\c
R1GS-1` q11
*** END OF FORM RWSCA 02102 ***
FORM: RWSCA 02102
Page 2 of 2
Attachment Order 3-a '

e
35*37!Z
39420c

39
39;
0
39:

Southern Soil Builders, Inc.
c/o C. Edwards 724 Duncan Road Rutherfordton, NC 28139
828)247-0067 [e-mail]
May 2, 2002
To: Water Quality Supervisor, DENR MAY - 7 2002
Interchange Building, 59 Woodfin Place
WATER UALITy SECTION
Asheville, NC 28802 AS'W''N l I Ir I?rMnnini fl_GIAC
Re: Watershed Classification for Biosolids Application Sites
City of Marion WQ#0019960
Attached please find 3 potential tracts with their topographic map locations as
proposed for land application of biosolids. Please complete the back of Form
RWSCA for watershed classification and return by mail to the address above at your
earliest convenience.
Do not hesitate to contact me if you have any questions or need additional
information.
Sincerely yours,
C0,0\j'\--�
Caroline J. Edwards
Licensed Soil Scientist #1220
Certified Land Application of Residuals Operator #23884
Southern Soil Builders, Inc. and Earthwise Designs

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
April 17, 2002
CITY OF MARION
LARRY CARVER
P.O. DRAWER 700
MARION NC 28752
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
0
M* 1 9 W
Subject: Acknowledgement of Application No.
WQ0019960
Land Application of Residual Solids
McDowell County
Dear Mr. Carver:
The Non -Discharge Permitting Unit of the Division of Water Quality (Division) acknowledges receipt of
your permit application and supporting materials on January 25,2002. This application package has been
assigned the number listed above.
Your application package has been assigned to Shannon Thornburg for a detailed review. The reviewer
will contact you with a request for additional information if there are any questions concerning your
submittal.
If you have.any questions, please contact Shannon Thornburg at 919-733-5083 extension 353, or via
email at [e-mail]. If the reviewer is unavailable, you may leave_ a message on
their voice mail, and they will respond promptly.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES
ON THIS PROJECT.
Sincerely,
,04�£im H. Colson, P.E.
Supervisor, Non -Discharge Permitting Unit
%��dY L34:r k
• ••11 [or! I I Lei I W to I gaxgy'11
E1'+�
Non -Discharge Permitting Unit Internet hftpJ/h2o.enr.nc.state.us/ndpu
1617 Mail Service Center, Raleigh, NC 27699-1617 Telephone [phone] Fax [phone]
DENR Customer Service Center Telephone [phone]
An Equal Opportunity Action Employer 50% recycled/10% post -consumer paper

A7L. 1. A
4 I' a
FqCDENR
North Carolina DeDartment of Environment and Natural Resources
Michael F. Easley, Govei.nor
Mr. Larry Carver, Supervisor
City of Marion
Post Office Drawer 700
Marion, North Carolina 28752
Dear Mr. Carver:
William G—Ross, Jr., Secretary
Gregory J. ThLrpe, Ph.D.
Acting Director
Division ol'Water Quality
Subject: Notice of Deficiency
City of Marion
Land Application of Wastewater Residuals
Permit Number WQ0019960
Dowell County
The purpose of this letter is to present deficiencies that have been discovered in your
Annual Land Application Certification Form. It is requested that you address the deficiencies
presented in this letter. Please respond in writing to the Asheville Regional Office, within 30 days
of receipt of this letter.
The following are the deficiencies that should be addressed:
• On page 3 of your package you note that you have averaged 3 percent solids samples
and entered the result on the Field Summary Form for site #R1 under % Solids. The
form specifically notes "Do Not Use Average".
• Field Summary Form for site # R1 indicates a failure to maintain an acceptable pH, a
violation of permit condition 11.4. The Soil Test Report indicates that 0.5 tons per acre
of lime was required for site # R1 on April 4, 2001, residuals were applied in August
2001, but lime was not applied until January 13, 2002.
On the Field Summary Forms for sites # R1 and # K1 the PAN numbers will be
incorrect once the change in % solids are made.
Asheville Regional Office, 59 Woodfin Place, Asheville, North Carolina 28801 Phone: [phone] Fax: [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled\110% Post Consumer Paper

Mr. Larry Carver
April 26, 2002
Page 2
• The fecal method utilized on Hydro Analytical Laboratories certificate of analysis was
not reported and should in accordance with permit condition 11.12.
• The final page of the report contains the results of VS In, VS Out and VSFR. These
have been calculated incorrectly. The actual VSR value should be 41.3% in
accordance with permit condition 1.12. EPA/625/R-92/013 Environmental Regulations
and Technology: Control of Pathogens and Vector Attraction in Sewage Sludge
guidance manual (White House Manual) should be consulted.
If you should have any questions regarding this or other water quality issues you may contact
me at [phone].
Sincerely,
arty Frost
Environmental Technician
xc: Kevin Barnett
Robert Boyette — City of Marion
Asheville Regional Office, 59 Woodfin Place, Asheville, North Carolina 28801 Phone: [phone] Fax: [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled\110% Post Consumer Paper

4'
J
ti
ANNUAL LAND APPLICATION CERTIFICATION FORM
Permit Number W00019960 County McDowell Year 2001
Facility Name (as shown on permit) City of Marion
Land Application Operator Southern Soil Builders Phone # [phone]
Land application of residuals as allowed by the permit occurred during the past calendar year
X YES NO . If NO, skip Part I and Part II and proceed to the certification. Also, if residuals were generated but not
land applied, please attach an explanation on how the residuals were handled.
Part I
• Total number of application fields in permit. 4 1
• Total number of fields land application occurred during the year. 2
• Total amount of dry tons applied during the year for all application sites. 89.4
l%r
• Total number of acres land application occurred during the year. 32
Part II
Facility was compliant during calendar year 2001 with all conditions of the land application permit (incsl�ii`n�but aft
not limited to items 1-12 below) issued by the Division of Water Quality C'o a
IF NO, PLEASE PROVIDE A WRITTEN DESCRIPTION WHY THE FACILITY WAS NOT COMPLIANT, THE DATES, AND E1;\Oi
CORRECTIVE ACTION TAKEN.
1. Only residuals approved for this permit were applied to the permitted sites.
2. Soil pH was adjusted as specified in the permit and lime was applied (if needed) to achieve a soil pH of at least'
6.0 or the limit specified in the permit.
3. Annual soils analysis was performed on each site receiving residuals during the past calendar year and three (3)
copies of laboratory results are attached.
4. Annual TCLP analysis was performed and three (3) copies of certified laboratory results are attached.
5. All other monitoring was performed in accordance with the permit and reported during the year as required and
three (3) copies of certified laboratory results are attached.
6. The facility did not exceed any of the Pollutant Concentration Limits in Table 1 of 40 CFR Part 503.13 or the
Pollutant Loading rates in Table 2 of 40 CFR part 503.13 . (applicable to 40 CFR Part 503 regulated facilities)
7. All general requirements in 40 CFR Part 503.12 and management practices in 40 CFR Part 503.14 were
complied with. ( applicable to 40 CFR Part 503 regulated facilities)
8. All operations and maintenance requirements in the permit were complied with or, in the case of a deviation,
prior authorization was received from the Division of Water Quality.
9. No contravention of Ground Water Quality Standards occurred at a monitoring well or explanations of
violations are attached to include appropriate actions and remediations.
10. Vegetative cover as specified in the permit was maintained on this site and the crops grown were removed in
accordance with the crop management plan.
11. No runoff of residuals from the application sites onto adjacent property or nearby surface waters has occurred.
12. All buffer requirements as specified on the permit were maintained during each application of residuals.
ICERTIFY, UNDER PENALTY OF LAW, THAT THE ABOVE INFORMATION IS, TO THE BEST OF MY KNOWLEDGE AND
BELIEF, TRUE, ACCURATE, AND COMPLETE. I AM AWARE THAT THERE ARE SIGNIFICANT PENALTIES FOR
SUBMITTING FALSE INFORMATION, INCLUDING THE POSSIBILITY OF FINES AND IMPRISIONMENT FOR KNOWING
VIOLATIONS"
Pe ittee Name and Title (type or print )
Sign tore of Preparer Date
(If different from Permlttee )
Note: Preparer is defined in 40 CFR Part 503.9(r)
IN

11
Permit Number
Facility Name
NPDES #
or WQ# (residual only facilities)
WWTP Name
ANNUAL RESIDUAL SAMPLING SUMMARY FORM
Attach this form to the corresponding laboratory analysis.
Please note that your permit may contain additional parameters to be analyzed than those required to be summarized on this form.
W00019960
City of Marion
NCO031879
Marion WWTP
Residual Analysis Data
Date Sampled 4 03 2001
rab or Date
Percent soilds 15.2
Laboratory Water Quailty Services, Inc.
Parameters (Mg/Kg (Mg/Kg
Arsenic
ary Wel
ni
3.1
Cadmium
0.21
Chromium
25.2
Copper
36.4
Lead
5.72
Mercury
0.16
Molybdneum
39.5
Nickle
7.9
Selenium
2.6
Zinc
82.2
TKN
1329
Ammonia - Nitrogen
105
Nitrate - Nitrogen
2.76
Total Phosphorus
291
x _ — K-
SIGNATURE OF PREPARER) (DATE)
"I certify, under penalty of law, that this document was prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the informaton submitted. I am aware that there are
significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."

i
Three samples were taken for percent solids around the basin.
They were as follows:
3.76%,
4%,
5.5%.
The average of the three combined samples was: 4.42%.
This is what was used to figure the field loading rates.

J14N-09-2002 04:16 PM MARION WWTP
CLIENT
ADDRESS:
CITY:
STATE:
I DIM:
Q914PENING CREEK
►TER QUALITY SERVICES, INC.
p.0. BOX 1102
BANNER ELK, NC 21004
(028) 733. 3142
LOGIN TIME:
SAMPLER:
RECEIVED DATE:
REPORTED DATE:
LAKKy GARVER
3-AP01
30-Apr-01
ZI NU
-
ALUMIUM
1100
105
<8.6
131.50
1.00
8.80
MG/KG SLUDGE
MG/KG SLUDGE
MG/KG SLUDGE
4/19/01 WTP
4/12/01 PI
4/30/01 PI
AMMONIA
grr :rGs
NITRATE tNITRITE — o i
1329
0.20
MG/KG SLUDGE
4/27/01 PI
TKN
TOTAL PHOS.
291
419.7
19.3
0.10
0.10
1.00
MG/KC
MWI(d
44
SLUDGE
SLUD©E
SLU009
4/27/01
4/30/01
dit3oroi
PI
PI
QI
P.A.N.
I-TOTALOOLID0
VOLITILE SOLIDS
MAGNESIUM
CALCIUM
POTASSIUM
A )alum
29.4
1.00
%
SLUDGE
4/30101
PI
2183
863.5
1
1514
32.
S5.80
32.90
MG/KG
MG/ KCi
MG/KG
tg_.0 IF
SLUDGE
4/18/01
PI
PI
PI
PI
09101
4/181g1
32.96
MWKG
4119/01
•- All QQ not MOt
REPORTED BY: NO CERTIFIED LAO $ 844
At�'
PAUL ISENHOUR, SUPERVISOR

J
S.
.JAN-09-2002 04:15 PM MARION wwUv
jUN-21-2001 THU 11:51 Ali FROMA QUALITY SERVICE$; FAX,82889862�5
WATER QUAUW SERVIC14, INC,
P.O. box 11 o7
BANNER ELK, NC 28W4
(924) 733- 3142
CLIENT:
ADDRESS,
CITY;
ETATM
IDS:
CORPiNING CURK
LQQIN TIME:
SAMPLER:
RECEIVED DATE:
RP-PORT1D DATE'
PAGE 1
LARRY CARVER
ma y-01
ANALY516
-. •
SLUR99
PI
CHROMIUM
26,2
1,00
MOtKO
LEAD
15,7
1,80
MOXG
SLUDGE
3/11141
PI
MOLYBDENUM
s9,6
1.80
m"a
BLU
11/01
P1
SFLFNIUMI
2.8
1.00
MGVKG
SLU
11V
PI
INITRATW+NITPtITE
2.78
2-00
momo
SLUDGE \
8/11/01
P!
RCrIJK 1 GU O 7 , rw vcr% r IF my rr+v ++
PAUL ISENHOUR, SUPERVISOR

.1 W.c. o..
r -R-
T
ANALYT .;.:RE ORY­
aorc N6nbb'n-:- 01'-A198�41
Y
Sample *:.
-ID;":-4210-106
-
p
Page 2
TCLP Results
Matrix 'Spi"
Analyte )Result Units. Reg - Limit'�Recovery Date. Time 6 Analyst Method QC Batch
---- ------ --- ------ --------
----------- ----- ---------- --------- -------- 71
- --------------------------
Pentachlorophenol < 0.0100 mg/1 .100 11.3 2/20%01 13:37 J.Gott 8270- .5836
Pyridine < 0,9100 mg/l. 5 . .0 92 2/20/01 13:37 J.Gott 8270 5830
2,4,5-Trichlorophenol < 0.0100 mg/1 .400 .--106 2/20/01 13:37 J.Gott 8270 5830
2,4,6-Trichlorophenol < 0.0100 mg/1 2.0 106 2/20/01 13:.37 J.Gott 8270 5830
Chlordane < G. . 0002 mg/1 0.030. :124'.,. 2/20/01 16:20 M. Cauthen .8081A 4791
2,4-D 0.160 2/20/`O1 16:19 R. Hunt .10.0 .75 . 8151A 5567
Endrin < 0.0002... mg/l 0.02 i17 -2/20/01.. . 16:20 M. . Cauthen 8081A 4791
Heptachlor , 0.0062 mg/1 0.008 822/20/01 16:20 H.. Cauthen 8081A 4791
Lindane < 0.0002 mg/l 0.4- 96 2/20 . /01. 16:20, H. Cauthen. 8081A 4791
Methoxychlor < 0.0002 mg/1 10.0 111 2/20/01 16:20 M. Cauthen 8081A 4791
Toxaphene < 0.0050 mg/i 0.50 103 2/20/01 16:20 K. Cauthen 8081A 4791
S i lv`A.1 < 0.0100 mg/ . 1 1. . 0 .73 2/20/ , 01 16:19 R . .. Hunt 8151A 5567
ueptalchlor epoxide < 0.0002 mg/1- '0.0081* '9.8 2/20/01 16:20 M. Cauthen 8081A 4791
TCLP Extraction Initiated 2/15/01. 16:00 K. Stewart 1311 2792
Zero fteadspace Extraction Initiated 2/15/61 16:0.0 K. Stewart 1311 2792
ND Not detected at the report limit.
Matrix Spike Recovery for TCUI analyiei reported'fkoin.Baich QC
TCLP prepartion follows method . 1311,'SW-84.6 Revi'si6n 3.
---------------- I -- -----------------------
------------ 7 ---------- ------ ----------- ---------------------------------
Sample Extracti6n Data
Wt/Vol
Parameter Extracted Extract Vol. -'Date Analyst :Method
..........
------------ ---- ------ -------- -----
TCLP Herbicides 5.0 ml 5. . 00 ml , 2417/01 D.Uager 3510
TCLP pesticides 100. ml 5.00-m1 J. Ruaden 3510
TCLP BMA's 560. ml 2/20/01 J.Gott 3510
Sample report continued.

OP `•:* ..
/
T
la
'.
%AN
:.Labo.ratory Number.::.01-A.19834
<Sample. ID': 210106
:.. .Project:. '_ L015.3'
Page. 3 . .
Surrogate
% Recovery
Target Range
BTEX/GRO Surr., a,a,a-TFT
Iil. '
• .1 �
50 • - 150.
VOA Surr, 1,2-DCA, d4
109.
71'. - 136.`
VOA Burr, Toluene d8
109-.
69. - 129.
VOA Surr, 4-BFB
98.
65. - 122.
surr-Nitrobenzene-d5
73..:
16. - 120.
surr=2-Fluorobiphenyi
82.
10. - 136.
surr-Terphenyl d14
64..
10. - 119.
surr-Phenol d5
67.
.10.• - 69.
Burr-2-Fluorophenol
10:
10., - 14$..
surr-2,4,6-Tribromophenol 94.•..
11. - 144,•
pest surr-TCPIX
40.
�.; 23..-.150,•
surr-Dibutylchlorendate
20.
10. - 120.
surr-DCPAA
.73.
10. - 161..
- Recovery outside Laboratory historical limits.
;
All results reported on a'wet weight basis.
These results relate only to the.i.tems.tested-.
This report shall not be. reproduced except . in. full and. with
permission of the laboratory:
Report Approved By:. Report Date: 2/24/01
Paul E.. Lane, Jr. , Lab Director. •: ` Gail A:': Lage; Technical Serv.
Michael H. Dunn, Ni.S'. , Technical Director Glenn L..IVortori, Technical Serv.
Johnn1.
y A. Mitohell, Dir. Techn cal'Serv. Kelly S. Comstock; Technical Serv.
Eric S. Smith, Assistant Technical -Director' Pamela A. Langford, Technical Serv.
Laboratory Certification Number: 387
End of Sample Report.

Client :
Water Quality Services, Inc.
P. 0. Box 1102
Banner Elk, NC 28604
Attention:
Mr. R. Trammel
Date Received:
4/ 17/2001
Report Date:
25-Apr-01
Sample Date:
16-Apr-01
BRL #:
BRL-2001-0342
Lab Sample 1D:
LSID-2001-01748
Client Sample ID:
104-660 Corpening Creek
Analysis Analysis
Parameter Result MQL Unit Method Time Date Analyst
Cvanide * 0.005 mg/1 EPA 335.2 11:17 4/24/01 KSM
Reported By:
. Matheson, S.J. Johnson
* Concentrations are b ow Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 4 of 4

„ JB-08-2001 FRI 03:33 PM FROM:WAT"° QUALITY SERVICES FAX:[phone] PAGE 2
6-08-2001 3�33PM FROM BLUE RIDGE LABS.INC. 704 728 0131 P 1
r,
6 Dos an • pme *%Moto tk
%"kW , NaCit CWQ W MO
• 'htsphoa� ts.A ta.ot�b
Client:
Wa= Qualk Smviow, bc-
P. O, Box 1102
Banner Elk NC 28604
Attention:
Mr. R Tnatul
Date Recta"ved:
5/30/2001
Rgwrt DaM
08-Jun-01
Sample Date:
22-May-01
SRL *I
BgU2001.0494
Lab Sameple, W.
LSO-2001-02322
Client Sennpie ID:
105-1303 CospaajtS Crook Sludge
'
Matyttitc
Aw►17Ab
Remit MOL
Unk Method
Time
Date
Arw�
Parameter r
0.1
-
=njwc 1030
.
17:17
6/5ro)
1C5M
-^ Baas ��
Nueva
6.40 0.1
su 9b45C SW-413�1
6/tSlD3
KSM
�, as PH
CWOdRenctivitYasCN
i 0.25
mP&S'..SW446-7.3.3
I 1W.
N5101
KSM
5
ing” SW446-7.3.3
15:11
6f8/Ol
KSM
Reactivity u SuMda
149
1uper and By.
1 aWeeoni $4. Ytbusaa
" Coroc,*.MW" an belaw Minimm QaNtreA t o Ltwt except whcoc no"
NC LalboMWY Cft1W $t Na 275
r�, pup I of 4

CITY OF MARION
Permit No. WQ0019960
Residuals Application Summary
SITE #
ACRES
UTILIZED
TOTAL
GALLONS
TOTAL
DRY TONS
GALLONS
PER ACRE
PAN
Ibs/acre
R1
16
210,000
38.7
13,125
2.1
K1
16
275,000
50.6
17,187.5
2.7
TOTALS
485,000
89.3

i
a
Annual Land Application Field Summary Form
PLEASE MAKE A COPY OF THIS BLANK FORM TO BE COMPLETED AND SUBMITTED FOR EACH APPLICATION FIELD.
PLACE AWN IN A BLANK OR BOX WHEN NOT APPLICABLE
FACILITY NAME: City of Marion
OWNER :Wayner Ross TOTAL DRY TONS APPLIED (ANNUAL): 38:7 PERMIT##: W00010960
CATION EXCHANGE CAPACITY (non 503 regulated facilities only) NA
OPERATOR: Wayner Ross SITE # R1 FIELD N
ACRES PERMITTED: 16 ACRES UTILIZED: 16
Gallons /or Cubic Yards
Totals:
Annual
Cumulative
Permit Limit (lbs./acre/year) -1 st Crop / 2nd Crop
Permitted Cumulative Pollutant Loading Rate (lbs./acre)
• t
SIGNATURE OF LAND PP ) DATE
"I certify, under penalty of law t this dument was prepared under my direction caccordance
t
with a system d gned to aswre that all qualified pereonnel property g1'submitted.
I am aware that there are signtflcant penalties for submitting false Info
�e
rk
for knowing violations."
Lime Applicatlon
DATE ILBSJACRE
P

f
Annual Land Application Field Summary Form
PLEASE MAKE A COPY OF THIS BLANK FORM TO BE COMPLETED AND SUBMITTED FOR EACH APPLICATION FIELD.
PLACE A'WA' IJ A BLANK OR BOX WHEN NOT APPLICABLE
FACILITY NAME: City of Marion
OWNER :Toua Kan g TOTAL DRY TO APPLIED (ANNUAL): 50.7 PERMIT #: WQ0019980
CATION EXCHANGE CAPACITY (non 603 regulated facilities only) NA
OPERATOR: Toua Kang SITE # K1 FIELD N
ACRES PERMITTED: 16 ACRES UTILIZED: 16
Date or Month
oanarts for Cubic Yards
(aPaclN)
Total perAcre
Dry TOM per % Solids Note: Do Mineralization Race Ap~lon Method
(Sacra"' ar kt(ection
Acre ReslduallSource Not Una Averages
■ reportirm by month keep
these day records on site
ea. cca� 1
lashes Faint"
Pae17411re pfy.Mea%W.t
Crop
112001
275,000
17188
3.17
WWTP
4.42
30%
surface 1
0
dry
fescue
0.00
0
0.00
0
0.00
0
0.00
0
0.00
0
0.00
0
0.00
0
0.00
0
0.00
0
0.00
0
0.00
o
Totals:
Annual
Cumulative
Lime Application
DATE LBB.lACRE
Perm It Limit (lbs.lacrefyear) -1 at Crop / 2nd Crop 1 250
Permitted Cumulative Poilutent Loading Rate (IbsJacre) 36 34 NA 1 338 267 15 NA 374 89 2 498
(SIGNATURE OF LAN�APII DATE
,,I certify, under penalty of law, Is document was prepared under my direction or supervision In
accordance with a system des ed to mature that all qualified personnel properly gathered and evaluated the Information
submitted. I am aware that there are significant penaltles for submitting false Information, Including the possibility of fines and Imprisonment for knowing violations:'

NCDA Agronomic Division
4300 Reedy Creek Road Raleigh, NC 27607-6465 _919 733-2655
Report No: 30693 f
Grower. Marion, City of
G'apies lo:
SOUthel'n Soil Builders
Land Application Biosolids Sites
Edwards, Caroline
PO Box 700
-�
Marion, NC 28752
R
Southern
Soil Builders
J�..,.
oZl est eft o rt
�J Fay;
958 Hoots
Rd.
•
1
Roaring
River, NC 28669
4/ 4/01
SERVING N.C. CITIZENS FOR OVER 50 YEARS McDowell County
Agronomist Comments:
Soil pH is lower than desired in some sample areas. Phosphorus is low in some samples. The heavy metal concentration is within the limits
of acceptable levels and should pose no threat to
crops grown on this land. The heavy metal results are shown on a separate report. Follow soil test recommendations for lime and fertilizer application rates. Note
zinc level in sample Q8. This
zinc level may cause problems with crop growth, if the zinc level continues to increase.
T. Kent Yarborough, Agronomist
Field Information
lied Lime
Recommendaf}ons
Sample No. Last Crop
Ho Yr T/A
Crop or Year Lime N Pa05 Kz0
Mg Cu
Zn B
Mn See Note
C1
1st Crop: Fes/OG/I'im,E 2.1T 50-70 140-160 20-40
0 0
0
0 12
2nd Crop: Fes/OG/I'im,M 0 120-200 140-160 60-80
0 0
0
0 12
Test Results
Soil Class HM% W/V
CEC BS% Ac pH P-I K-I Ca% Mg% Mn-1 Mn-AI (1)Mn-AI (2) Zn-I
Zn-AI
Cu-I S-I
SS -I NO3-N NIL-N Na
MIN 0.76 .0.
5.4 57.0 2.3 5.3 0 36 38.0 16.0 164 108 108 35
35
83 127
0.1
Field lnformatron
8004 Lune
Recommendations
Sample No. w Last Crop
Mo Yr T/A
Crop or Year Lime N R05 h0
Mg Cu
Zn B
Mn See Note
KI Fes/OG/Tim,M
1st Crop: Fes/OG/Pim,M 0 120-200 0 0
0 0
0
0 12
2nd Crop:
Test Results
Soil Class HM% W/V
CEC BS% Ac pH P-I K I Ca% Mg% Mn-I Mn-AI (1) Mn-AI (2) Zn-I
Zn-AI
Cu-I S-1
SS -I NO3-N NIL-N Na
MIN 0.97 0.97
10.8 82.0 1.9 6.1 87 94 63.0 15.0 308 200 166
166
73 60
Field Informat>0n
8110he"d Lime
Recommendations
Sample No. Last Crop
Mo Yr T/A
Crop or Year Lime N P205 Kz0
Mg Cu
Zn B
Mn See Note
K2 Tree, Shade
1st Crop: Fes/OG/Pim,E 1.8T 50-70 110-130 0
0 0
0
0 12
2nd Cro ): Fes/OG/Pim,M 0 120-200 100-120 0
0 0
0
0 12
Test Results
Soil Class HM% W/V
_.----�` ��--- �
CEC BS% Ac pH P-I K-I ' Ci �AI (2) Zn-I
Zn-AI
Cu-I S-1
SS -I Nt Nlfi-N Na
0.1
MIN 0.97 1.01
8.6 76.0 2.1 5.8 13 113 5( 297 158
158
34 47

ronomic Division
4300 ReedyCreek Road Raleigh, NC
27607-6465
919 733-2655 Grower: Marion, City of
Report No: 30693 P �2,
PInformation
Applied
Lime
Recommendations
Sample No. Last Crop
o
Yr T/A
Crop or Year
me
N Pr05 KO
Mg Cu
Zn
B
Mn
See Note
RI Fes/OG/Pim,M
Ist Crop: Fes/OG/Pim,M
120-200 0 U
0 0
0
12
2nd Crop:
Test Results
Soil Class HM% W/V CEC
BS% Ac pH P-I K-I
Ca%
Mg%
Mn-1 Mn-AI (1) Mn-AI (2) Zn-1
Zn-AI
Cu-1
S-1
SS -I
NO3-N NIA-N Na
MIN 1.14 0.85 ' 11.3
83.0 1.9 5.8 122 124
54.0
23.0
157 111 155
155
54
109
0.3
Field Information
lied Lime
Recommendations,
Sample No. Last Crop
o
~ Yr T/A
Crop or Year
Lime
N R05 KO
Mg Cu
Zn
B
Mn
See Note
Q1 Fes/OG/Pim,M
Ist Crop: Fes/OG/Pim,M
0
120-200 0 0
0 0
0
0
12
2nd Crop:
Test Results
Soil Class HM% W/V CEC
BS% Ac pH P-I KI
Ca%
Mg%
Mn-I Mn-AI (1)Mn-AI (2) Zn-I
Zn-AI
Cu-I
S-I
SS -
MIN 0.71 1.09 10.7
79.0 2.3 6.1 340 90
59.0
15.0
161 112 456
456
492
48
Field Information.
8pplipd.1ime_
Recommendations -
Sample No. Last Crop
Mo
,
Yr T/A Crop or Year
Lime
N ROs h0
Mg Cu
Zn
B
Mn
See Note
Q2 - Small Grains
Ist Crop: Corn,Silage
0
180-220 0 10-30
0 0
0
0
3
2nd Crop: Small Grains
0
80-100 0 0
0 0
0
0
3
Test Results
Soil Class HM% W/V CEC
BS% Ac pH P-I K-I
Ca%
Mg%
Mn-I Mn-AI (1) Mn-AI (2) Zn-I
Zn-AI
Cu-1
S-1
SS -I
NO3-N NIfrN Na
MIN 0.76 1.06 10.2
79.0 2.1 6.0 301 103
62.0
12.0
768 478 471 346
346
470
55
0.1
Feld_Informatton -�
lame
�Recommendattons
, _
Sample No. Last Crop
.. _lied
Mo Yr T/A
Crop or Year
Lime
N R05 h0
Mg Cu
Zn
B
Mn
See Note
Q3 Corn,Silage
Ist Crop: Small Grains
.3T
80-100 0 0
0 0
0
0
3
2nd Crop: Corn,Silage
0
180-220 0 0-20
0 0
0
0
3
Test Results
Soil Class HM% W/V CEC
BS% Ac pH P-I K I
Ca%
Mg%
Mn-1 Mn-AI (1) Mn-AI (2) Zn-I
Zn-AI
Cu-1
S-I
SS-1
NO3-N NL&N Na
MIN 0:2 0.7
8.8
78.0 1.9 5 301 119
58.0
13.0
501 311 318 324
324
432
55
Field Information
lied Lime
Recoinmendatiois„
J
Sample No. Last Crop
o
Yr T/A
Crop or Year
Lime
N ROs h0
Mg Cu
Zn
B
Mn
See Note
Q4 Tree, Shade
Ist Crop: Fes/OG/Tim,E
1.1T
50-70 90-110 0-20
0 0
0
0
12
2nd Crop: Fes/OG/Pim,M
0
120-200 80 100 40 60
0 0
0
0
12
Test Results
Soil Class HM% W/V CEC
BS% Ac pH P-1 K-1
Ca%
Mg%
Mn-1 Mn-AI (1) Mn-AI (2) Zn-1
Zn-AI
Cu-I
S-I
SS-1
NO3-N Nlf-N Na
MIN 0.27 1.18
3.9
69.0 1.2 5.6 20 45
49.0
15.0
175 114 114 52
52
92
143
0.1

r
r
FACILITY NAME:
WWTP NAME:
ANNUAL PATHOGEN & VECTOR ATTRACTION REDUCTION FORM
Southern Soil Builders
Marion WWTP
Monitoring Period: From 1 / 1 101 To 12 131 101
Permit Number. WQ0019960
NPDES A N00031879
Pathogen Reduction ( 40 CFR 603.32) - Please Indicate level achieved and altemathre performed
Class A
Alternative 1 A@emattve 2 AltemaWe 3
Alternative 4 Alternative 6 Alternative 6
Class B X
Alternative 1 A Alternative 2 Alternative 3
If applicable to alternative performed (Class B only) Indicate " Process to Significantly Reduce Pathogens " :
Aerobic Digestion _ Air Drying Anaerobic Digestion Composting Lime Stabilization
If applicable to alternative performed (Class A or Class B) complete the following monitoring data:
Parameter
Allowable Level In
Sludge
Pathogen Density
Number of
Exceedences
Frequency of
Analysis
Sample
Type
Analytical
Technique
Minimum
Geo. Mean
Maximum
units
Fecal Coliform
2), 10 (6) MPN per
gram of total soilda gr
2 x 10(6) CFU per
gram of total solids
1000 MPN per gram
of total solid (dry
weight)
Salmonella bacteria (in
3 MPN per grams
lelu of fecal coliforrn)
total solid (dry weight)
Vector Attraction Reduction ( 40 CFR 503.33 ) - Please indicate option performed
Option 1 X
Option 6 _
Option 2 _
Option 7 _
Option 3 _
Option 8 _
No vector attraction reduction options were performed
CERTIFICATION STATEMENT ( please check the appropriate statement)
Option 4 _
Option 9 _
Option 5 _
Option 10 _
X " I certify, under penalty of law, that the pathogen requirements In 40 CFR 503.32 and the vector attraction reduction requirement In
40 CFR 503.33 have been met.
" I certify, under penalty of law, that the pathogen requirements In 40 CFR 503.32 and the vector attraction reduction requirement In
40 CFR 503.33 have not been met. "( Please note if you check this statement attach an explanation why you have not met one or both of the
requirements.) ,
" This determination has been made under my direction and supervision in accordance with the system designed to ensure that qualified
personnel properly gather and evaluate the information used to determine that the pathogen and vector attraction reduction requirements
have been met. I am aware that there are significant penalties for false certification Including fine grid Imp
S.'sonrpQl
O �e. � �N S O �s c
Preparer Name and Title (type or print) Land A h r Name and Title (ice p i le) (type or print)
Si n e of Preparer Date Signature of Land Appller (if le) Data

HYDRO AnALYTICAL LABORATO _-ES
630H 0 Ramada Drive, Box C-2 Clemmons, NC 27012
[phone]
.-� Fax [phone]
CERTIFICATE OF ANALYSIS
AMENDED REPORT
May 29, 2001
CLIENT NAME
HMS MARION
CLIENT NUMBER
80000399
210106
210107
210107
210107
210107
210107 210107 210107
SAMPLE NUMBER
2112/01
2/12/01
2/12/01
2112101
2/12/01
2112101 2112101 2112/01
COLLECTED DATE
2/13101
2113101
2113101
2113101
2/13101
2113/01 2/13/01 2/13/01
RECEIVED DATE
CORP CRK
CORP CRK
CORP CRK
CORP CRK
CORP CRK
CORP CRK CORP CRK CORP CRK
DESCRIPTION
CLASS B
CLASS B
CLASS B
CLASS B
CLASS B
CLASS B CLASS B CLASS B
A
B
C
D
E F G
TEST
UNITS
RESULTS
RESULTS
RESULTS
RESULTS
RESULTS
RESULTS RESULTS RESULTS
SOLIDS
%
14.9
16.0
14.9
15.2
15.3
15.3 15.2 15.5
FECAL SLUDGE
MPN/GRAM
2667
5369
4636
11111
PH
SU
MG/L
6.13
ATTACHED
TCLP
I'
12.
3672 MPN/GRAM
CERTIFICATION # NC 103
NC 37733
CERTIFIED BY:
MICHAEL 4RELTON
LAB MANAGER

A-19-2001 THU 10:27 AM FROM:WAT" ;QUALITY SERVICES
FAX:[phone]---,
PAGE 2
WATER QUALITY SERVICES, INC.
P.O. BOX 1102
BANNER ELK, NO 28604
[phone]
CLIENT: CORPENING CREEK WWTP LOGIN TIME.
ADDRESS: SAMPLER:
CITY: RECEIVED DATE:
STATE: REPORTED DATE:
ID#: NC0031879
11:30 AM
ROBERT WALKINS
12-Jul-Oi
y4W.,
••LOCA.T.
LLES.ULT&
ITS"
W EE--'
- SA P.
I. N166MO�LE:
6-
? ANALYSIS'irl
TE D1
INTANAL':
BOO 5 DAY
240.0
2.00
MG/L
I
18-Jul-01
Pi
UL' 0 L'�'T
BOO 5 DAY
3.3
2.00
MGJL
E
18-Jul-01
PI
TOTAL A�SUSPENDED RESIDUE
L SUSPENDED
330
1.00
MG/L
16-Jul-01
WTP
OTAL SUSPENDED RESIDUE
TOTAL
<1
1.00 1
MG/L
E
15-Jul-01
WTP
AMMONIA. NITROGEN
<0.10
0.10
MG/L
E
17-Jul-01
WTP
FECAL COLIFORM
327
1.00
PERM 00
U
13-Jul-01
PI
FECAL COLIFORM
200 ast
1.00
PERM 00
E
13-Jul-01
PI
IFECAL COLIFORM
406
1,00
PERM 00
D
--13-Jul-01
PI
MHOS/CM
U
WTP
CONDUCTIVITY .-.20.00
CONDUCTIVITY
. 20.00
MHOS/CM
E
WTP
CONDUCTIVITY
1.20.00
MHOS/Cm
D
WTP
OIL&GREASE
1.00
MG/L-
E
PI
TOTAL NITROGEN
0.60
MG/L
E
PI
0. Is
MG/L
E
E
Pi
P I
TOTAL PHOS,
CADMIUM
0.50
UG/L
0.50
MG/L
PI
COPPERE
11350.00
1.00
NIGIL
inf
19-Jul-01
P11
P1
MLSS
8720.00
1.00
MGIL
sludge
19-Jul-01
PI
MLVSS
92020.00
1.00
MG/L
19-Jul-01
Pi
MLSS
MLVSS
14020.00
1,00
MG/L
digester
Jul-01-
19-Jul
PI
w- All QC not met.
REPORTED BY: NC CERTIFIED LAB 0 544
f��
PAUL ISENHOUR, SUPERVISOR

vp
VS In 0.014
Vs out 0.0087
VS F R 0.381894
M
\01�` ^

CITY OF MARION
P.O. Drawer 700
Marion, North Carolina 28752
To: Larry Frost
Division of Water Quality
Environmental Technician
Asheville Regional Office
OFFICE OF THE
WASTE TREATMENT
PLANT SUPERVISOR
Subject: Permit Modification
Permit Number WQ0019960
City of Marion
Corpening Creek Wastewater Treatment Plant
Mr. Frost
Here is your copy of the letter I sent to Shannon and a copy of the report. Thank
you for your help.
JG
Larry Carver, WWTP Supervisor
i
l

CITY OF MARION
P.O. Drawer 700 OFFICE OF THE
r�
WASTE TREATMENT
Marion, North Carolina 28752 PLANT SUPERVISOR
To: Shannon Thornburg
DENR/DWQ/Water Quality Section
Non -Discharge Compliance Unit
1617 Mail Service Center
Raleigh, N.C. 27699-1617
Subject: Permit Modification
Permit Number: WQ0019960
City of Marion
McDowell County
Mrs. Thornburg
As per our phone conversation on 2/20/2002 about this permit, The City has not
generated any Class A solids for disposal since 1999. We are now land applying Class B
solids under our new permit and will no longer need to keep this permit open
WQ0008681. There was no activity to report under this permit in 2001. However I would
like to request the opportunity to resend this permit and to modify our existing Class B
land application permit WQ0019960 to except the use of our stabilization unit as a back
up plan to our aerobic digestion. In the event we have to use this process we will still land
apply on our permitted fields as Class B. I feel that this will add to the effectiveness of
our operation and provide us with additional coverage. I would like to take this
opportunity to thank for all your help.
L
Larry Carver, WWTP Supervisor

3 I ANNI 'LAND APPLICATION CERTIFICATION ':M
Permit Number LJ & 000 S6 F� County 03c b6,j e � k . Year
Facility Name (as shown on permit) C: ,' h of iv t k ► tin
Land Application Operator f/`� _Phone # FS `d.SS (osoZ �S`-�3
Land application of residuals as allowed by the above permit occurred during the past calendar year
YES Y,,r NO. If NO, SKIP PART I, AND PART II AND PROCEED TO THE CERTIFICATION. ALSO, IF RESIDUALS WERE
GENERATED BUT NOT LAND APPLIED, PLEASE ATTACH AN EXPLANATION ON HOW THE RESIDUALS WERE HANDLED.
Part I
• Total number of application fields in permit.
• Total number of fields land application occurred during the year.
• Total amount of dry tons applied during the year for all application sites.
• Total number of acres land application occurred during the year.
Part II
Facility was compliant during calendar year 200_ with all conditions of the land application permit (including but not limited to
items 1-12 below) issued by the Division of Water Quality
YES NO. IF NO, PLEASE PROVIDE A WRITTEN DESCRIPTION WHY THE FACILITY WAS NOT COMPLIANT, THE
DATES, AND EXPLAIN CORRECTIVE ACTION 'TAKEN.
1. Only residuals approved for this permit were applied to the permitted sites.
2. Soil pH was adjusted as specified in the permit and lime was applied (if needed) to achieve a soil pH of at least 6.0 or the
limit specified in the permit.
3. Annual soils analysis were performed on each site receiving residuals during the past calendar year and three (3) copies of
laboratory results are attached.
4. Annual TCLP analysis was performed and three (3) copies of certified laboratory results are
attached.
5. All other monitoring was performed in accordance with the permit and reported during the year as required and three (3)
copies of certified laboratory results are attached.
6. The facility did not exceed any of the Pollutant Concentration Limits in Table 1 of 40 CFR Part 503.13 or the Pollutant
Loading Rates in Table 2 of 40 CFR part 503.13. (applicable to 40 CFR Part 503 regulated facilities)
7. All general requirements in 40 CFR Part 503.12 and management practices in 40 CFR Part 503.14 were complied with.
(applicable to 40 CFR Part 503 regulated facilities)
8. All operations and maintenance requirements in the permit were complied with or, in the case of a deviation, prior
authorization was received from the Division of Water Quality.
9. No contravention of Ground Water Quality Standards occurred at a monitoring well or explanations of violations are
attached to include appropriate actions and remediations.
IO.Vegetative cover as specified in the permit was maintained on this site and the crops grown were removed in accordance
with the crop management plan.
I LNo runoff of residuals from the application sites onto adjacent property or nearby surface waters,has occurred.
12.All buffer requirements as specified on the permit were maintained during each application of residuals.
"I CERTIFY, UNDER PENALTY OF LAW, THAT THE ABOVE INFORMATION IS, TO THE BEST OF MY KNOWLEDGE AND BELIEF,
TRUE, ACCURATE, AND COMPLETE. I AM AWARE THAT THERE ARE SIGNIFICANT PENALTIES FOR SUBMITTING FALSE
INFORMATION, INCLUDING THE POSSIBILITY OF FINES AND IMPRISONMENT FOR KNOWING VIOLATIONS."
1�y Ae2 I � e-�� (_416 A del c D� Zd O Z
Permittee Name and Title (type or print) ign ure of Permiittee Date
i Hato Preparer Date
(if different from Pere ttee)
Y U Zd
Signature of Land Applier Date
(if different from Permittee and Preparer)
Note: Preparer is defined in 40 CFR Part 503.9(r) DEM FORM CF (1/2002)

ANNUAL DISTRIBUTION AND MARKETING/ SURFACE DISPOSAL CERTIFICATION AND SUMMARY FORM
FACILITY NAME (i I_V I�A�Ic rvi .� 1'� PERMIT # LJ4P C-O Fi'`&S I COUNTY!' C- I) 6LJ a `` OPERATOR
FACILITY TYPE (please check one): ❑ Surface Disposal (complete Part A (Source(s) and "Residual IN" Volume only) and Part C) PHONE
❑ Distribution and Marketing (complete Parts A, B, and C)
WAS THE FACILITY IN OPERATION DURING THE PAST CALENDAR YEAR? YES NO. If NO, skip Parts A, B, and C and certify form below.
Part A'
Part B'
Month
Sources(s)
(include NPDES # if applicable
Volume (dry tons)
Recipient Information
Admendment/
Bulking Agent IN
Residual IN
Product OUT
Name(s)
Volume
dry tons
Intended use(s)
January
February
- -A eAe
I.SG�+� �
rU c
� J !
n71
�1
1 &-
�2 �✓�
' !larch
April
May
June
July
August
September
October
November
December
Totals:
Annual (dry tons)
r-,
Admendment(s) used: Bulking Agent(s) used:
If more space is required than given, please use the comment space provided below or attach additional sheet(s). LJ
Comments:
Check box if additional sheet(s) are attached.
rt C
Facility was compliant during calendar year 200_ with all conditions of the permit (including but not limited to items 1-3 below) issued by the
Division of Water Quality YES NO. If NO, please provide a written desription why the facility was not compliant.
1. All monitoring was performed In accordance with the permit and reported during the year as required and three (3) copies of certified laboratory results are attached.
2. All operations and maintenance requirements were compiled with or, in the case of a deviation, prior authorization was received from the Division of Water Quality,
3. No contravention of Ground Water Quality Standards occurred at a monitoring well.
"I CERTIFY, UNDER PENALTY OF LAW, THAT THE ABOVE INFORMATION IS, TO THE BEST OF MY KNOWLEDGE AND BELIEF, TRUE, ACCURATE AND COMPLETE. I AM AWARE THAT '
THERE ARE SIGNIFICANT PENALTIES FOR SUBMITTING FALSE INFORMATION, INCLUDING THE POSSIBI ITY OF FINES AND IMPRISONMENT FOR KNOWING VIOLATIONS."
IG TURE OF PERMITTEE DATE I UR O EPARER' DATE
(if different from Permittee) 'Preparer is defined In 40 CFR Part 503.9(r)
DEM FORM DMSD (1/2002)

ANNUAL RESIDUAL SAMPLING SUMMARY FORM
Attach This form to the corresponding laboratory analysis.
Please note that your permit may contain additional parameters to be analyzed than those required to be summarized on this form.
Permit Number (-jQ g Laboratory 1)
Facility Name C,T__o,����,.i 2)
NPDES # evCD a ( 2 `79 3)
or WQ #
WWTP Name
Residual Analysis Data
Date Sampled or
Date Com osited
Percent Solids
Chromium
��■��w��������
IG ATURE OF PREPARER) DATE
"I certify, under penalty of law, that this document was prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. I am aware that there are
significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
DEM FORM SSF (1/2002)

ANNUAL LAND APPLICATION FIELD SUMMARY FORM
PLEASE MAKE A COPY OF THIS BLANK FORM TO BE COMPLETED AND SUBMITTED FOR EACH APPLICATION FIELD.
PLACE A "N/A" IN A BLANK OR BOX WHEN NOT APPLICABLE.
FACILITY NAME C,-kA L � , LJ PERMIT # t SaO00
OWNER �° l �4 SITE # CATION EXCHANGE CAPACITY (non 503 regulated facilities only)
OPERATOR FIELD # ACRES PERMITTED ACRES UTILIZED
TOTAL DRY TONS APPLIED (ANNUAL) /lip-P
Gallons /or Cubic Yards % Solids Mineral- Applicatior If reporting by month keep
DATE or s eci Dry Tons (Do not zation Rate method* these daily records on site
er Acre Residual Source use Inches Site Conditions. Crop
MONTH Total per Acre p see code Rainfall past
p Averages) (Dry, Moist, Wet)
TOTALS:
Permit Limit (lbs./acre/year) - 1 st Crop / 2nd Cr
Permitted Cumulative Pollutant Loading Rate
1
Lime Application
DATE I LBS./AC.I
* Code
S - Surface
I - Incorporation
IN - Injection
LBS JACRE
P JAsJCdJCrJCuJPbJ.HgJIVIoJ Nil Sel Zn
X
(SIGNATURE OF LAND APPLIER) DATE
"I certify, under penalty of law, that this document was prepared under my direction or supervision. in accordance with a system
DEM FORM FSF(1/2002designed to assure that qualified personnel properly gathered and evaluated the infonlnation submitted. I am aware that there are.
lignificant penalties for submitting false Information, including the possibility of fines and imprisonment for knowing violations."

ANNUAL PATHOGEN AND VECTOR ATTRACTION REDUCTION FORM
Facility Name iz I /lU\ n Permit Number L J (SLo aL F (pT
WWTP Name CL� ea-1 I -L)f) C/Zee k C.J t IJ NPDES # IU d v 3 J R ?
Monitoring Period: From _/_/_ TO
Pathogen Reduction (40 CFR 503.32) - Please indicate level achieved and alternative performed
Class A_ IvO �bl t 5 L,�e Ke
Alternative 1
Alternative 4 _
Alternative 2 _
Alternative 5
Alternative 3
Alternative 6
Composting _Heat Drying _Heat Treatment _Thermophilic _Beta Ray _Gamma Ray _Pasteurization
Class B
Alternative 1_ Alternative 2 Alternative 3
If applicable to alternative performed (Class B only) indicate "Process to Significantly Reduce Pathogens":
Aerobic Digestion _ Air Drying _ Anaerobic Digestion _ Composting _ Lime Stabilization
If applicable to alternative performed (Class A or Class B) complete the following monitoring data:
Parameter
Allowable Level
in Sludge
Pathogen Density
Number of
Exceedences
Frequency of
Analysis
Sample
Type
Analytical
Technique
Minimum
Geo. Mean
Maximum
Units
Fecal Coliform
2 x 106 MPN
per gram of total
solids or 2 x 1 CP
CFU per gram
of total solids
1000 MPN
per gram of
total solid
(dry weight)
Salmonella
3 MPN per 4
bacteria (in
grams total
lieu of fecal
solid (dry
coliform)
weight)
Vector Attraction Reduction (40 CFR 503.33) - Please indicate option performed
Option 1 Option 2 Option 3 Option 4 Option 5
Option 6 Option 7 Option 8 Option 9 Option 10
No vector attraction reduction options were performed
CERTIFICATION STATEMENT (please check the appropriate statement)
-I certify, under penalty of law, that the pathogen requirements in 40 CFR 503.32 and the vector attraction reduction
requirement in 40 CFR 503.33 have been met."
`'I certify, under penalty of law, that the pathogen requirements in 40 CFR 503.32 and the vector attraction reduction
requirement in 40 CFR 503.33 have not been met." (Please note if you check this statement attach an explanation why you have not met one
or both of the requirements.)
"This determination has been made under my direction and supervision in accordance with the system designed to ensure that
qualified personnel properly gather and evaluate the information used to determine that the pathogen and vector attraction
reduction requirements have been met. I am aware that there are significant penalties for false certification including fine and
imoriSonrnent."
IIJ
Preparer ame and Title (type or print)
Qn a of Preparer Date
Land Applier Name and Title (if applicable)(type or print)
Ai
Signature of Land Applier (if applicable) Date
DEM FORM RF (1/2002)

Michael F. Easley
Governor
William G.'Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
Asheville Regional Office
WATER QUALITY SECTION
August 3, 2001.
Mr. Larry Carver
Wastewater Supervisor — City of Marion
Post Office Drawer 700
Marion, North Carolina 28752
Subject: Land Application — Information,
Permit No. WQ0019960'
City of Marion
McDowell County
Dear Mr. Carver,
I want to apologize for the delay in getting the following, information to you. The
following are the web sites that you asked for last week;
• http://www.epa.gov/epahome/publications.htm
• http://h2o.enr.state.nc.us/ndceu/app/application.htmI
• http://www.wef.org/TechinfoCtr/
Again, thank you for your patients regarding this matter. Should you have any
questions regarding these sites please let me know at [phone] or my e-mail
address larry.frostCa)-ncmail.net.
Sincerely,
O .
Lar Frost
Environmental Technician
.r
Water Quality Section, 59 Woodfin Place, Asheville, NC 28801-2414 Telephone: [phone] Customer Service
Fax: [phone] 623-7748

North Carolina
Department of Environment and Natural Resources
Water Pollution Control System Operator Certification Commission
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Coleen H. Sullins, Chairman
August 6, 2001
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. J. Robert Boyette, City Manager
.City of Marion
P.O. Box 700
Marion NC 28752
7A
Ad
NCDENR
Subject: Classification of Land Application/Residuals System
System: City of Marion
Permit No: WQ00019960
County: McDowell
Dear Mr. Boyette:
The Water Pollution Control System Operators Certification Commission adopted Rule 15A NCAC 8G .0305,
Classification of Land Application/Residuals Systems, effective April 1, 1999. In order. to insure the proper
operation and maintenance of these systems, this Rule requires that all facilities which are permitted for the land
application of sludge, residuals, biosolids, or contaminated soil on a dedicated site to be classified as land
application/residuals systems.
The Water Pollution Control System Operators Certification Commission hereby classifies the subject facility as
a Land Application/Residuals System.
As required by Rule 15A NCAC 8G .0202 (2) and the subject permit, a certified operator and back-up operator
of the appropriate type must be designated for each classified system. Your system requires an Operator in
Responsible Charge (ORC) and a back-up operator who hold valid land application/residuals certificates
If you have not already done so, please complete and return the enclosed designation .form to this office by
September 10, 2001. Failure to designate a properly certified Operator in Responsible Charge and back-up
operator is a violation of the permit issued for this system.
If you have any'questions or need additional information concerning this requirement please call Tony Honeycutt
at 919-733-0026, extension 314.
Enclosure
ccaff�r
Central Files
TAC Facility Files
Sincerel
Tony nold, Acting Supervisor
Tech cca1 Assistance -and Ce. if a£i : U''i1
-
1 jfl AUG - 9 2001.
1618 Mail Service Center, Raleigh, North Carolina .27699-1618
Phone: 919 — 733-0026 \ FAX: 919 — 733-1338
AN EQUAL OPPORTUNITY \ AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED / 10% POST CONSUMER PAPER

1
State of North Caroling_.
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Kerr T. Stevens. Director
�JV(21001 �_721—Pl
MEMORANDUM
TO: ��Office
Tom a wa a er, roun w on
FROM: Theresa Nartea, Soil Scientist-NDPU
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
in.,
_m
JUL 2 2001
WAf ER QUALi3`i SE�;TiON
ASHEViLLE i<EGMMI.OFFICE
RE: Additional information response: WQ0019960-City of Marion
For your files. Thanks!
1617 Mail Service Center, Raleigh, North Carolina 27699:1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

IEZAR7HMME DES%, DOHS
724 Duncan Road Rutherfordton, NC 28139
June 25, 2001
To: Theresa Nartea
Soil Scientist, Non -Discharge Permitting Unit o.
Division of Water Quality, NCDENR
Re: Submittal of Supplemental Information �2
City of Marion Land Application of Residuals Project s�v
Permit # WQ0019960
Dear Ms. Nartea:
Enclosed is the information requested in your letter dated May 9, 2001; and five (5) copies
are being mailed to you. The attached information details the numbered items which
correspond to the items in your query. We appreciate the effort on your part to facilitate
this process.
If you have any questions regarding this information, -you may contact me at 828) 247-
0067 or mobile# [phone]; or Mr. Robert Boyette, Marion City Manager, at 828)652-
3551.
Sincerely,
C'
Caroline J. Edwards
Licensed Soil Scientist #1220
Land Application of Residuals Operator #23884
Enc.
cc: Robert Boyette, Manager, City of Marion

June 19, 2001
Report prepared by Earthwise Designs for the City of Marion
WWTP Land Application of Biosolids; Permit #WQ0019960
Additional information As requested, Items 1 - 6
1) The signature of Toua Khang is already on the Land Application form at the top right as
part owner; it is the unreadable scribbled one. Your confusion is understandable.
2) Residuals information is provided herein.
3) Reactivity, Ignitability, and Corrosivity analyses are provided herein.
4) Fecal analyses results reported in MPN/gram and geometric mean are provided
herein.
5) Application Item V. 1. b. 5. (revised page 4) is provided herein and shows the options
planned for this facility: when volitile . solid reduction to 38% cannot be obtained by
present equipment, then option f. (Alkaline Stabilization) will be utilized. The certified
biosolids hauler will document this stabilization process and keep on file the time and
pH of the residuals so as to provide documentation of the process.
6) Due to the very low amounts of all nitrogen forms in the analysed residuals the organic
nitrogen mineralization rates are not calculated; they are negligible.
-Corrections: on page 2. of the LARS form "800 tons" was written in error: it has been
corrected to the figure "290 dry tons" which is projected as an estimated upper limit if
operating conditions occur which approach the design flow. Although the actual need for
it is unlikely, the facility requests the flexibility to expand its residuals management
program up to 290 dry tons during this permit period as conditions allow for plant
expansion or construction. Improvement of this facility is planned in the future.
•A revised Supplemental Table of Contents is attached; also pages 1 - 4 of the LARS
form.

Supplemental Infc__iation - June 2001
TABLE OF CONTENTS
CITY OF MARION
CORPENING CREEK WASTEWATER TREATMENT PLANT
SUPPLEMENTAL INFORMATION FOR.
APPLICATION FOR A
NON -DISCHARGE PERMIT
LAND APPLICATION OF BIOSOLIDS
JUNE 2001
LETTER
Outline of Sections A. - C.
A. GENERAL & ANALYSIS
Introduction
PAGES 1-4; 11-14 (subs.) of North Carolina Form LARS 02/95
Total Sludge; Reactivity 'etc.; Fecal Coliform Analysis
B. SITE DELETED
##4) Site Q - Frank Queen
C. AGRONOMY
Agronomist Report - new RYE Data

SECTION A
GENERAL & ANALYSIS

Supplemental Intormation - June 2001
I. INTRODUCTION
The City of Marion hereby supplies additional information as requested in order
to apply for a non -discharge permit for land application of residuals produced
from the Corpening Creek Wastewater Treatment Plant as described herein.
The City proposes to generate up to 290 dry tons annually of biosolids and
permit 79.5 acres of farmland. The three (3) landowners have agreed to utilize
the biosolids application program as described in the permit application: This
program will result in an economic savings to these landowners in McDowell
County by providing important nutrients necessary for crop growth. These
landowners have eagerly agreed to have biosolids applied to their . land at
agronomic rates to be used as a fertilizer supplement.
II. OUTLINE OF APPLICATION INFORMATION
A. GENERAL & ANALYSIS
General: This section contains revised pages 1 through 4 including the updated
proposed acreage figures; corrected annual dry tonnage production estimates;
and selected vector attraction reduction requirement methods that are planned.
Residual Analysis: information not submitted in the original permit application
package for the residuals from the primary digester: Calculations, Application rate
evaluations, the SAR calculation and Site Life figures generated by the applicant
in lieu of pages 11 - 14 of 18. Organic nitrogen mineralization calculations were
not included since the N rates would be so low as to be negligible. This section
also contains reports on Total Sludge and Fecal Coliform Analysis with the
requested additions.
B. SITE
SITE #4 owned by Frank Queen 'has been deleted from the permit package at
this time due to neighborhood concerns about the application of poultry litter on
the site.
C. AGRONOMY
This section contains additions to the Agronomist's Report with
recommendations taking into account realistic yield expectations (RYE) data for
the soils on the three sites.

State of North Carolina
I.
Department of Environment, Health and Natural Resources
Division of Environmental Management
Non -Discharge Permit Application Form
(THIS FORM MAY BE PHOTOCOPIED FOR USE AS AN ORIGINAL)
LAND APPLICATION OF RESIDUAL SOLIDS
This application is intended for residuals which will be regulated under 40 CFR Part 503
GENERAL INFORMATION:
1. Applicant's name (please specify the name of the municipality, corporation, individual, etc.):
City of Marion
2. Print Owners or Signing Official's name and title (the person who is legally responsible for the facility and its compliance):
J. Robert (Bob) Boyette. City Manager
3. Mailing address: P. O. Box 700
City: Marion State: NC Zip: 28752
Telephone Number. ( 828) 652-3551
4. Application Date: June 2001
5. Fee Submitted: $ *Prev.Subm. [The permit processing fee should be as specified in 15A NCAC 2H .0205(c)(5).]
6. Specify whether these residuals will be land applied to: X agricultural lands, forest, public contact sites,
reclamation sites; (Please be advised, if these residuals will be distributed for lawn or home garden use, the
application for the "DISTRIBUTION OF RESIDUAL SOLIDS" should be completed rather than this application.)
7. If the alternative for residual disposal consists of "surface disposal" .as defined under 40 CFR Part 503, please complete the
application titled "SURFACE DISPOSAL OF RESIDUAL SOLIDS. Please identify if there is any storage of residuals in
a surface impoundment or disposal thru landfilling. Explain:
N/A
8. For Class B Residuals (or Class A Residuals to be land applied on a dedicated site), please specify the number of acres on
which residual solids are to be land applied under the authority of this permit:
proposed in this application: 79.5 acres; total (current and proposed): 79.5 acres
9. County(ies) where residuals will be land applied: McDowell
II. PERMIT INFORMATION:
1. Application No. (will be completed by DEM):
2. Specify whether project is: X new;' renewal*; _ modification
For renewals, complete all sections included in the application, in' addition, please submit updated cumulative loadings
for the ten (10) pollutants and updated owner's agreement for each site.
3. If this application is being submitted as a result of a renewal or modification to an existing permit, list the existing permit
number and its issue date
FORM: LARS 02/95 Page 1 of 18-

. III. FACILITY INFORMATION (attach additional pages for additional sources of residuals):
1. Name of facility where residuals are generated or prepared City of Marion WWTP
2. Facility permit number. NCO031879 ; facility permit holder. City of Marion
3. Specify whether facility in Section III.1 is owned by: federal; private; state; X local government.
4. Specify facility design flow: 3.0 MGD; facility average daily flow: 0.800 MGD;
Type of residual storage: 1 Sludge Thickening Tank: 1 Extended Air Tank
Volume of residual storage: 130,000 gal in sludge thickening tank: ext. air tank holds 0.78 MG
Length of residuals storage at facility: 30+ * days (the Division requires a minimum 30 days storage in units that are
separate from treatment system, i.e. not in clarifiers, aeration basins, etc.); (holding tank, etc.)
Maximum storage time of residuals between application events: 90 (est.) days. *Plant storage capabilities are being
upgraded to meet the needs of the land application of residuals program*
Estimated volume of residuals: 290 (dry tons/yr.);
5. Are there any other storage facilities, other than the above, currently on site: Yes, X No.
6. Facility contact (person familiar with residuals preparation): Larry Carver WWTP ORC
7. Facility contact's telephone number: ( 828 ) 652-8843 at WWTP
8. Location of treatment facility: Marion. NC State; McDowell County
9. Mailing address: City of Marion
P. O. Box 700
Marion, NC 28752
10. Latitude/Longitude: WWTP: 350 39' 11" 810 57' 22"
11. Specify the source of the residuals: X treatment of domestic wastewater; X treatment of industrial wastewater;
other (explain):
Attach an explanation of either the treatment process, manufacturing process, or how the waste is generated. Provide full
and complete details of the entire process.
12. Does the facility which generates the residuals have an approved pretreatment program? X Yes; No.
This includes facilities which are classified as a "Class I" facility (any publicly owned treatment works required, under 40
CFR 403.8, to have an approved pretreatment program or any facility treating domestic sewage that is classified as "Class
I" by the appropriate federal or State authority)
IV. RESIDUALS INFORMATION (attach additional pages for additional sources of residuals):
1. Information for Hazardous Waste (RCRA) Determination. The information requested on the limitations specified below
pertain only to those residuals that are generated from.a:municipal wastewater treatment facility with industrial contribution
or active pretreatment program and from any other treatment facility with wastewater sources that include industrial sources.
a. Are any of the residuals covered by this application listed in 40 CFR 261.31-261.33? Yes; X No. If Yes,
list the number(s):
b. Do the residuals exhibit any of the four characteristics defined by 40 CFR 261.21-261.24? Yes; X No.
Attach laboratory results for the Toxicity Characteristic Leaching Procedure Analyses, Reactivity, Ignitability, and
Corrosivity for each residual.
Note : If the following constituent levels (as determined by the Toxicity Characteristic Leaching Procedure Analyses) are
exceeded in the residuals or if the pH of the residual is not within the range listed below, the residual is by
definition a Hazardous waste. Chemical analyses must be made to Minimum Detection Levels.
FORM: LARS 02/95 Page 2, of 18

PPM PPM
Arsenic
5.0
Barium
100.0
Benzene
0.5
Cadmium
1.0
Carbon tetrachloride
0.5
Chlordane
0.03
Chlorobenzene
100.0
Chloroform
6.0
Chromium
5.0
o-Cresol
200.0
m-Cresol
200.0
p-Cresol
200.0
Cresol
200.0
2,4-D
.10.0
1,4-Dichlorobenzene
7.5
1,2-Dichloroethane
0.5
1,1-Dichloroethylene
0.7
2,4-Dinitrotoluene
0.13
Endrin
0.02
Heptachlor (and its hydroxide)
0.008
Hexachlorobenzene
0.13
Hexachloro-1,3-butadiene
0.5
Hexachloroethane
3.0
Lead
5.0
Lindane
0.4
Mercury
0.2
Methoxychlor
10.0
Methyl ethyl ketone
200.0
Nitrobenzene
2.0
Pentachlorophenol
100.0
Pyridine
5.0
Selenium
1.0
Silver
5.0
Tettachloroethylene
0.7
Toxaphene
0.5
Trichloroethylene
0.5
2,4,5-Trichlorophenol
400.0
2,4,6-Trichlorophenol
2.0
2,4,5-TP (Silvex)
1.0
Vinyl chloride
0.2
pH (2:1 vol./wt.): >2.0 s.u. - <12.5 s.u.
NOTE: IF ANY OF THE RESIDUALS MEET THE DEFINITIONS OF A HAZARDOUS WASTE,
AS NOTED IN EITHER "A" OR "B" ABOVE, A PERMIT CANNOT BE ISSUED FOR
THAT RESIDUAL AND IT SHOULD NOT BE INCLUDED AS PART OF THIS
APPLICATION.
2. For each residual, please attach a complete chemical analysis of the material. This analysis must be comprehensive enough
to completely characterize the residual and must be based upon a review of the process that generates the material. If the
facility that will generate the residual is not yet in operation, the characterization must be based on similar existing
facilities and projection based on the type of facility. The analysis must include a minimum of the following parameters
and any other known and suspected contaminants that are tributary to the system.
Arsenic
Molybdenum
Cadmium
Nickel
Chromium
Selenium
Copper
Zinc
Lead
Aluminum
Mercury
Ammonia -Nitrogen
Calcium
Phosphorus
Magnesium
Potassium
Nitrate -Nitrite Nitrogen
Sodium
% Total Solids
TKN
pH
Plant Available Nitrogen
(by calculation)
3. Wastewater residuals shall not be applied to the land if the concentration of any pollutant in the residuals exceeds the ceiling
concentrations specified in the table below. Specify the pollutant concentration of these residuals (attach lab analysis):
Pollutant
Pollutant Ceiling Concentration (mg/kg)
'Dry Weight Basis
Pollutant Concentration (mg/kg)
Dry Weight Basis
Arsenic
75
3.1 (4/3/01)
Cadmium
85
0.21
Chromium
3000
25.2
Copper
4300
36.4
Lead
840
5.72
Mercury
57
0.16
Molybdenum
75
39.5
Nickel
420
7.9
Selenium
100
<0.66
Zinc
7500
1 82.2
FORM: LARS 02/95 Page 3 of 18

V . PATHOGEN AND VECTOR ATTRACTION REDUCTION INFORMATION (attach additional pages for
additional sources of residuals):
1. In accordance with 40 CFR Part 503, a residual can not be land applied if it does not meet one of the following alternatives
for Class B pathogen reduction.
a,b5 Please specify a, bl, b2, b3, b4, b5 or c from below (submit all lab analysis, test results and calculations):
a. at least seven residuals samples should be collected at the time of use and analyzed for Fecal coliforms during each
monitoring period. The geometric mean of the densities of these samples will be calculated and should be less than
2,000,000 most probable number per gram of total dry solids, or less than 2,000,000 Colony Forming Units per gram
of total dry solids.
b. the residuals must be treated by -one of the following "Process to Significantly Reduce Pathogens" (PSRP).
1. Aerobic Di esg. tion - residuals are agitated with air or oxygen to maintain aerobic conditions for a specific mean cell
residence time and temperature between 40 days at 200 C and 60 days at 150 C.
2. Air Drying - residuals are dried on sand beds or on paved or unpaved basins for a minimum of three months.
During two of the three months, the ambient average daily temperature is above 00 C.
3. Anaerobic Digestion - residuals are treated in the absence of air for a specific mean cell residence time and
temperature between 15 days at 350 C to 550 C and 60 days at 200 C.
4. Composting, - using either the within -vessel, static aerated pile, or windrow composting methods, the temperature
of the residuals are raised to 400 C or higher for five days. For four hours during the five days, the temperature in
the compost pile exceeds 550 C. .
5. Lime Stabilization - sufficient lime is added to the residuals to raise the pH of the residuals to 12 after two hours
of contact.
c. The residuals shall be treated by a process that is equivalent to a "Process to Significantly Reduce Pathogens" (PSRP),
as determined by the permitting authority, based on an evaluation of the recommendations provided by the Pathogen
Equivalency Committee.
2. In addition, when residuals are being land applied, at least one of the following vector attraction reduction requirements (a,
b, c, d, e, f, g, h, i, or j) described below must be met.
a: f Specify the letter(s) of the vector attraction reduction requirement that have been met (submit lab results, test results
and calculations). Any variation of the below must be described in full detail and attached.
a. Aerobic or Anaerobic Digestion - The mass of volatile solids are reduced by at least 38%. Volatile solids reduction is
measured between the residuals, prior to stabilization, and the residuals ready for use or disposal. This criterion should
be readily met by properly designed and operated anaerobic digestors, but not as readily met by aerobic digestors.
Treatment facilities with aerobic digestors may need to meet the vector attraction reduction requirement through 18c or
18d.
b. Anaerobic Digestion - If 38% volatile solids reduction cannot be achieved, vector attraction reduction can be
demonstrated by further digesting a portion of the previously digested residuals in a bench scale unit for an additional
40 days at 300 C to 3.70 C. If, at the end of the 40 days, the volatile solids are reduced by less than 17%, vector
attraction reduction is achieved.
c. Aerobic Digestion_ - If 38% volatile solids reduction cannot be achieved, vector attraction reduction can be demonstrated
by further digesting a portion of the previously digested residuals that have a solids content of 2% or less in a bench
scale unit for an additional 30 days at 200 C. If, at the end of the 30 days, the volatile solids are reduced by less than
15%, vector attraction reduction is achieved.
d. Aerobic Di esg_tion, - The specific oxygen uptake rate (SOUR) shall be equal to or less than 1.5 milligrams of oxygen
per hour per gram of total dry solids at 200 C.
e. Aerobic Processes - The temperature of the residuals for at least 14 days shall be greater than 400 C. During this time,
the average temperature shall be greater than 450 C.
f. Alkaline Stabilization - The pH of the residuals is raised to 12 or higher by alkali addition and, without the addition of
more alkali, remains at 12 or higher for 2 hours and then at 11.5 or higher for an additional 22 hours.
FORM: LARS 02/95 Page 4# of 18

Earthwise Designs
Rutherfordton, NC
April, May, & June 2001 sampling
Project: City of Marion CORPENING CREEK WHIP
Sample Date: 04/03/01
- class B sludge
% SOLIDS:
15.2 pH: 5.13
CONVERSION
TABLE
PARAMETER
mg/kg = ppm dry wt
x 0.002
=1bs/dry ton
Nit. TKN
1329.
Phosphorus
291.
0.6
Potassium
1566
3.1
Calcium
863.8
1.7
Magnesium
2163
4.3
Sodium
1514
3.0
Ammonia N
105
Nitrate N
<6.6
Ceiling
Iron
N
Concent.
N
Aluminum
1100
ppm
2.2
Copper
36.4
4,300.00
Cu
0.0728
Zinc
82.2
7,500.00
Zn
0.1644
Cadmium
0.21
85.00
Cd
0.0004
Chromium
25.2
3,000.00
Cr
0.0504
Nickel
7.9
420.00
Ni
0.0158
Lead
5.72
840.00
Pb
0.0114
Arsenic
3.1
75.00
As
0.0062
Mercury
0.16
57.00
Hg
0.0003
Selenium
<0.66
100.00
Se
0.0013
Molybdenum
39.5
75.00
Mo
0.079
PLANT AVAILABLE NITROGEN CALCULATION (PAN)
TKN - AmN x 30% + 1/2.AmN + NO3N x 0.002 = lbs. PAN/dry ton
Surface 0.94 lbs PAN/dry ton
-f .1.` (5 voo--+-)

CALCULATION WORK SHEET - Class B
Project: Citv_of Marion WASTEWATER TREATMENT PLANT
Total dry tons to be applied yearly: (est.) 290 dry tons
Total PAN to be land applied: 274 in lbs.
Total min. acres needed each year: 68.5 ac. at 4 lbs PAN/ac
Project: City of Marion CORPENIN CREEK WWTP
Sample Date: 04/03/01
- class B sludge
% SOLIDS:
15.2 pH: 5.13
ONVERSION TABLE
PARAMETER
mg/kg = ppm dry wt
x 0.002
=lbs/dry ton
Nit. TKN
1329.
Phosphorus
291.
0.6
Potassium
1566
3.1
Calcium
863.8
1.7
Magnesium
2163
4.3
Sodium
1514
3.0
Ammonia N
105
Nitrate N
<6.6
Ceiling
Iron
-
Concent.
N
Aluminum
1100
ppm
2.2
Copper
36.4
4,300.00
Cu
0.0728
Zinc
82.2
7,500.00
Zn
0.1644
Cadmium
0.21
85.00
Cd
0.0004
Chromium
25.2
3,000.00
Cr
0.0504
Nickel
7.9
420.00
Ni
0.0158
Lead
5.72
840.00
Pb
0.0114
Arsenic
3.1
75.00
As
0.0062
Mercury
0.16
57.00
Hg
0.0003
Selenium
<0.66
100.00
Se
0.0013
Molybdenum
39.5
75.00
Mo
0.079
PLANT AVAILABLE NITROGEN CALCULATION (PAN)
TKN - AmN x 30% + 1/2 AmN + NO3N x 0.002 = lbs. PAN/dry ton
Surface 0 94 lbs PAN/dry ton
�.12 C�WD

Project: City of Marion Corpening Creek
WASTEWATER Treatment Plant
SAR = 2.43
SAR = Na meq / [.5 (Ca meq + Mg meq)]1/2
% Solids = 15.2
10.0 meq Na
6.5 meq Ca
27.4 meq Mg
To convert wet weight values to milliequivalents (meq):
Na: atomic wt. 23, valence 1
meq. =wet weight Ca: atomic wt. 40, valence 2
atomic wt./valence Mg: atomic wt. 24, valence 2
wet weight = mg/kg X % solids
,V>. \3 �%&b)

WATER QUALITY SERVICES, INC.
P.O. BOX 1102
BANNER ELK, NC 28604
(828) a�a4-2-
q
CLIENT: CORPENING CREEK LOGIN TIME:
ADDRESS: SAMPLER: LARRY CARVER
CITY: RECEIVED DATE: 3-Apr-01
STATE: REPORTED DATE: 30-Apr-01
I D#:
:ANALYSIS
.:.RESULTS
AN,4LYSIS:.:MQL's
UNiTS:
SAMPLEA
LOCATION,
ANALYSIS
COMP_LETED
INT .
ARSENIC
3.1
0.66
MG/KG
SLUDGE
4/19/01
PI
CADMIUM
0.21
0.03
MG/KG
SLUDGE
4/19/01
PI
CHROMIUM
<65.8
65.80
MG/KG
SLUDGE
4/19/01
WTP
COPPER
36.4
32.90
MG/KG
SLUDGE
4/19/01
WTP
LEAD
<65.8
65.80
MG/KG
SLUDGE
4/19/01
i
WTP
MERCURY
0.16
0.11
MG/KG
SLUDGE
4/23/01
PI
MOLYBDENUM
<32.9
32.90
MG/KG
SLUDGE
4/19/01
PI
NICKEL
7.9
6.60
MG/KG
SLUDGE
4/19/01
PI
SELENIUM
<0.66
0.66
MGIKG
SLUDGE
4119/01
WTP
ZINC
82.2
32.90
MGIKG
SLUDGE
4/19/01
WTP
ALUMIUM
1100
131.60
MG/KG
SLUDGE
4/19/01
WTP
AMMONIA
105
1.00
MG/KG
SLUDGE
4/12/01
PI
NITRATE + NITRITE
<6.6
6.60
MG/KG
SLUDGE
4/30/01
PI
TKN
1329
0.20
MG/KG
SLUDGE
4/27/01
PI
TOTAL PHOS.
291
0.10
MG/KG
SLUDGE
4/27/01
PI
P.A.N.
419.7
0.10
MG/KG
SLUDGE
4/30/01
PI
TOTAL SOLIDS
15.2
1.00
%
SLUDGE
4/30/01
PI
VOLITILE SOLIDS
29.4
- 1.00
%
SLUDGE
4/30/01
PI
MAGNESIUM
CALCIUM
2163
863.8
32.90
MG/KG
SLUDGE
4/19/01
PI
PI
65.80
MG/KG
4/19/01
POTASSIUM
SODIUM
1566
1514
1 32.90
MGIKG
I SLUDGE
4/19/01
PI
PI
1 32.90
MG/KG
4/19/01
'- HII UU not met
REPORTED BY: NC CERTIFIED LAB # 544
PAUL ISENHOUR. SUPERVISOR

v L1 Z.v1�'1 <<, 11 j1 1u1 111v:T1.11111L,11 '4VnL•111 QLIV1l,C:u rnn.VL00i0UL'J7 rn�,� I
WATER QUALITY SERVICES, INC.
P.O. BOX 1102
BANNER ELK, NC 28804
(528) 733- 3142
CLIENT: CORPENING CREEK LOGIN TIME:
ADDRESS: SAMPLER: LARRY CARVER
CITY: RECEIVED DATE: 8-May-01
STATE: REPORTED DATE, 11-May-ol
10#:
ANALYSIS
FANALYSlS.
MQL's
::: , :
UNITS'
:.00ATION:.C.OMPLETED
['6-AMPLE
ANALYSIS
INTRE*VLTS
CHROMIUM
25.2
1.80
MG/KG
SLUDGE
5/1l/o1
Pi
LEAD
5,72
1.00
MG/KG
SLUDGE
5/11101
Pi
MOLYBDENUM
39.5
1.80
MG/KG
SLUDGE
5/11/01
PI
SELENIUM
2.6
1.80
MG/KG
SLUDGE
5/11/01
PI
FN71TRATE * NITRITE
QGor%o,r=,l ❑\/. A1/• f AM .0
2.76
2.00
MG/KG
SLUDGE
5/11/01
P1
_... __ � •._ �.�...., .�._. vw m .dam"•
PAUL ISENHOUR, SUPERVISOR

Client:
Water Quality Snrvicas, Inc.
P. 0, Box 1102
Saw= E44 NC 28604
Attention.
Mr. R. Trammel
Date. Recm, td:
5/30/2001
Report Date:
08-Jun-01
Sample Date:
22-May-O 1
RRLrat
BR-2001.0494
Lab Sample M.
LSID-2001-02322
Client Sample ID:
105-1303 Corpwting Greek Sledge
1°aramctcr _ • .
Rauh hd L
_ Q
Flsit
Mettod
Amalysix
Tim
Analysts
Matta
Analyst
Bun Ratc
Ne*vvc 0.1
nun/sac
1030
17,17
61;101
KSM
CormsMry as PH
6.40 0.1
su
9945C SW4
13:01
6/6rol
KSM
ReactMty as CN
0.25
mgkg•
SW$46-7.3.3
17V
U5101
KSM
Reactivity o3 SulSde
149 3
Mglkg
SW-W T 3.3
15.11
6A/01
KSM
KUL Msthesott, $4. johaaaa
Conceniratims arc bd ow Aiinimum Qu&nttt3CatlOn Limit escxpt wkre noted.
NC Laboratory CertW=te No. 275
N9C 1 of 4

Client :
Water Quality Services, Inc.
P. 0, Box 1102
Banner Elk, NC 28604
Attention:
Mr. R. Trammel
Date Received:
4/.17/2001
Report Date:
25-Apr-O l
Sample Date:
16 Apr-O l
BRL #:
BRL-2001-0342
Lab Sample ID:
LSID-2001-01748
Client Sample ID:
104-660 C:orpening Creek
Parameter
Result MQL
Cvanide
0.00�
Analysis Analysis
Unit Method Time Date Analyst
mg/1 EPA 335.2 11:17 4/24/01 KSN1
Rej)orted By:
5. ,Vlatheson, S.J. Johnson
i Concentrations are li w Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
P,we 4 of 4

June 25, 2001
CLIENT NAME
CLIENT NUMBER
SAMPLE NUMBER
COLLECTED DATE
RECEIVED DATE
DESCRIPTION
TEST
% SOLIDS
FECAL SLUDGE
pH
TCLP
CERTIf=1CATION #
CERTIFIED BY:
ANALYTICAL. LABORATORIES
6300 Ramada Drive, Box C-2
Clemmone, NC 27012
[phone]
Fax [phone]
TIFICATE OF ANALYSIS
AMENDED REPORT
HMS MARION
80000399
210106
210107
210107
210107
210107
210107
210107
210107
2112101
2112101
2112101
2112/01
2M 2101
2/12/01
2112101
2112/01
2113101
2113101
2M 3/01
2113101
2/13/01
2113101
2113/01
2113101
CORP CRK
CORP CRK
CORP CRK
CORP CRK
CORP CRK
CORP CRK
CORP CRK
CORP CRK
CLASS 8
CLASS B.
CLASS B
CLASS 9
CLASS 6
CLASS B
CLASS 8
CLASS B
A
B
C
D
E
F
O
UNI
RESULTS
RESULTS
RESULTS.
RESULTS
RESULTS
RESULTS
RESULTS
RESULTS
%
14.2
15.0
14.9
15.2
15.3
15.3
15.2
15.5
MPNIG
M
2$67
$369
4636
11111
1307
1316
7097
S
5.13
MG
ATTACHED
FECAL SLUDGE GEOMETRIC MEAN:
" 3672 MPNIGRAM
NC 103
NC 37733
MICHAEL SHtfL.TON
LAB MANAGER

SECTION B
#4 - SITE Q , Fields 1 - 10 owned by Frank Queen were deleted previously
due to concerns raised by regional Groundwater Personnel during a site visit.
Neighbors were expressing their concern with the unpleasant odor from the
spreading of chicken litter on some of these fields. The City of Marion
determined it was in the best interests of all to avoid spreading city -generated
residuals on fields that are already experiencing a public relations situation.

SECTION C
AGRONOMIST REPORT - RYE. DATA
City of Marion Corpenin_q Creek Wastewater Treatment Plant
AGRICULTURAL UTILIZATION / LAND APPLICATION OF BIOSOLIDS"
Fields C1, K1, K2, AND Mare managed as pasture and hay for cattle feed with the
cool -season grasses fescue and orchardgrass as the primary forages. These 3 sites
(C, R, and K) are all upland sites mapped as Hayesville clay loam, 6-15% slopes,
eroded (HcC2). The RYE data suggest that a multiplication factor ranging from 0.8 to
0.92 be used on the 0 to 10 % slopes that will be land applied; and that a Hayesville
soil would be expected to grow 6 tons of fescue hay under a high level of management.
Thus using this data one could project fescue hay production of 4.8 to 5.5 tons/acre.
The agronomic chart in the original permit package used a figure of 4 tons as an
average yield/acre.
Regardless of which data is used the biosolids from the City at 0.94 Ibs of PAN/dry ton
will not supply all of the agronomic needs of the pasture or hay crop. Additional
fertilizer (NPK) will need to be supplemented by the landowner.
Annual soil testing and annual crop yields will need to be monitored by each
landowner for maximum crop production.

State of North Carolir
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
NCDENR
William G. Ross, Jr., Secretary
Kerr T. Stevens, Director
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
June 26, 2001
MEMORANDUM
j z
TO: L_ o �_ _ .. _17 0Diana ce
�! JUN 2 8 2001 1
19 C
Tom Cadwallader, Groundwater Section
WATER QUALITY 5E----�jij Ij
�SHEVfi1C ��Gfi3�,C��:=�
FROM: Theresa Nartea, Soil Scientist-NDPU
RE: Additional information response: WQ0019960-City of Marion
For your riles. Thanks!
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

JUN-25-01. MON 16:28 .0+0-(-0E0^F0E04'0*-0E0 828 247 0067 P.01
FAX COVER SHE
TO: Non -Disc lharcge ''jcQnp>lance Unit
Division of Water Q.uality, NCDENR
ATT: Theresa Nartea;, Boil Scientist
FROM:
EARTHWISE DESIGN,EC►
AROLINE EDWAR11143)
724 Duncan Road Ruffle %0ordton, NC. 28189
ph/fax.[phone] KA11 ,b.828)289-0122
Total sheets inc. COVEl r: 5)
mm

Ne
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
WATER POLLUTION CONTROL SYSTEM OPERATORS CERTIFICATION COMMISSION
1618 MAIL SERVICE CEV" RALEIGH, NORTH CAROLINA 27699-1618
40NE 919-733-0026 FAX [phone]
AN EQ OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER _ o RECYCLED/10% POST -CONSUMER PAPER

JUN-25-01 MON 16 :31 _ . i0i+0*-0E0t0E-0410<-0#0 £328 247 0067 P. 04
.. �.i "'-WE EVALUATION SH:rTT
Field#: ._..�__��� Date: �—Q
Predominate Soil Series: G" q: sir' M_ aP'Q CL
Depth of Seasonal High Water Table:
Depth, Type of Restrictive Zone:
Slope:
Field Analysis of Soils
FDenth-., X kn Textuinr Structure Matrix Color Mottle Cnlnr
Ck
�
C..
�
-S �( �
_
Legend
Texture: s - sand Structure: a - granular
Is - loamy sand wsbk - weak subangular blocky
sl - sandy loam msbk - medium subangular blocky
set - sandy clay loam ssbk - strong subangular
cl - clay loam 5O1t gL,�
I - loam G�
J.
sc - sandy cllay
sic - silty clay
c - clay '
sit - sift. loam
!. A .�
sicl - silty clay loam
12.0
11 { C,&,
Type of crop CAA

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
WATER POLLUTION CONTROL SYSTEM OPERATORS CERTIFICATION COMMISSION
1618 MAIL SERVICE CEP'--^ RALEIGH, NORTH CAROLINA 27699-1618
HONE 919-733-0026 FAX [phone]
AN EQ 7PPORTUNITY / AFFIRMATIVE ACTION EMPLOYER K. RECYCLED/10% POST -CONSUMER PAPER

JUN-25-01 MON :16:32 0j>0*-OE0<-0E0E0F0E0 828 247 0067
S[']fE EVALUATION SHEET
P.05
I D
Operator: _ - �} :__-: Q>ti
Field#: (r----t-� `
Predominate Soil Series:��
Date: S ^ 12 — a I
�Q tt
Depth of Seasonal High V6'ater. Table: - -
Depth, Type of Restrictive Zarne: S 60
Slope:
Field Analvsis of Soils
Depthi\ Texture structure Matrix Color Mottle Color
t
S
Legend
Texture: s - sand Structure: a - granular
Is - loamy sand wsbk - weak subangular blocky
sl - sanely loam msbk - medium subangular blocky,
scl - sandy &ay loam ssbk - strong subangular blocky
cl - clay 14--am
1 - loarrn SO►� SC��
sc - sandy clay
Sic - si[t;f clay
c - clay
sil - silt loain
sicl - silky clay loam
l� 1220
tjCQ c1
Type , of Crop

` NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
WATER POLLUTION CONTROL SYSTEM OPERATORS CERTIFICATION COMMISSION
1618 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1618
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - SO% RECYCLED/10% POST -CONSUMER PAPER

JUN-25-01 MON 16:30
. 0->0<0¢0<-0<-0<-0<-0<-0
828
247 0067
Ed
J"vALUATION
SHIFT
P.03
Operator:
r�
Field.#:
Predominate Soil Series:
Date: � a-S —
Depth of Seasonal High Water~'][`able:--
Depth, Type of Restrictive Zone:
Slope: -
Field AnalvAs of Soils
rn.nih TPvtftre Structure Matrix Color Mottle Color
011
_� �__•
l !V' f
Texture: s - sand
Is - loamy sand
st - sandy loam
set - sancly clay loam
cl - eta, loam
1 - loam
sc - san-:11 clay
sic - silted' clay
c - clay
A - sil1JORM
sic] - silih; ,.-day loam
T' pe oil Crop
Lend
Structure: g - granular
wsbk - weak subangular blocky
msbk - medium subangular blocky
ssbk - strong subangular blocky
S411 SCf�
J.
d1' �
1220
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IMLAr
vwwwl NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
� 7
1 . 0. 0
WATER POLLUTION CONTROL SYSTEM OPERATORS CERTIFICATION COMMISSION
1618 MAIL SERVICE CEP"--- RALEIGH, NORTH CAROLINA 27699-1618
HONE 919-733-0026 FAX [phone]
AN EQ, OPPORTUNITY / AFFIRMATIVE 'ACTION EMPLOYER __.o RECYCLED/10% POST -CONSUMER PAPER

JUN-25-01 MON 16 :29 ®}B< 0E0{0f0E 0{0E0 828 247 0067 P. 02
t►ITE (EVALUATION SHEET
Operator: ,y,,.T- V aLk-OD
Field#:
Predominate Soil Series:
Depth of Seasonal ]High �'Vater
Date: j %CQ lot
Depth, Type of Restrictive Zone: e g
Slope:
., Field Analvsis of Soils
",�._ _�-
ilPnlh Texture Structure Matrix Color Mottle Color
3�
Rt�'
52
Cs
rk
2 I�
Texture: s - sand
is - loarny sand
sl - sandy loam
scl --sandy clay loam
cl - clay loam
I - loam
sc -sandy clay
sic - silty clay
c - clay
sil - silt loam
sicl - silty clay loam
Type of Crop
Legend
Structure: g - granular
wsbk - weak subangular blocky
msbk - medium subangular
ssbk - strong subangu lL SCa�
J. ,igrrj � JiJ,.,►
m
mow°.++► �
1220`�
0L�( 1 SC- — 1t+1
� e

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
WATER POLLUTION CONTROL SYSTEM OPERATORS CERTIFICATION COMMISSION
1618 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1618
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER PAPER

add 7, 8 9 on Subject: Application No. WQ0019960
Subject: add 7, 8 9 on Subject: Application No. WQ0019960
Date: Mon, 25 Jun 2001 17:12:10 -0400
From: Caroline —Edwards <[e-mail]>
Organization: Earthwise Designs
To: [e-mail]
CC: [e-mail]
To: Theresa Nartea
From: Caroline Edwards, Earthwise Designs
Subject: Application No. WQ0019960
Additional Information Request
City of Marion
Land Application of Residual Solids
McDowell County
Thanks Theresa for sending the letter again. I mailed the packet out
today for Items 1 - 6, you should get it tomorrow.
Here is the additional information for Items 7 - 9, and more on 6:
Item 7 (Calc. Work sheet) I sent today all the information that is on
those sheets but in a format that my software can deal with. In the past
this has been acceptable and I hope it will be to you also.
Item 8: same response as for Item 5. The certified hauler will provide
documentation showing pH and time verification of proper Alkaline
Stabilization method.
Item 9: I stamped and signed each of the 4 Soil Evaluation Sheets and
will fax you a copy. Is this a requirement now, it hasn't been before?
The signed/sealed report was sufficient in the past.
Note on Item 6, already sent: The Residual Analysis showed an unusually
low reading of N, which is why I did not figure the org. N
mineralization rate. I suggest that when the WWTP samples in the next
quarter they send it out to a different laboratory to update the N
figures. Then if they are higher such that organic N is an issue, at
that time figure the mineralization rate, if indeed it is actually
necessary to do so; it has not been so in the past due to the amount of
land acreages in the programs being such that it generally takes 2 to 3
years to get around to all the fields. For Marion I don't think the N
rates will be high enough to track organic N; much to the landowners'
sorrow!
Thank you for your assistance on this project. Let me know if you need
anything else at: ph/fax also: 828)247-0067
Watch for the Soil Evaluation Sheets fax.
Sincerely,
Caroline J. Edwards
Lic. Soil Scientist #1220
Land Application of Residuals Operator #23884
cc: Robert Boyette, Manager, City of Marion
1 of 1 6/26/01 7:16 AM

:... r -L
a
June 30, 2017
J. Robert Boyette, City Manager
City of Marion
PO Drawer 700
Marion, NC 28752
SUBJECT: Annual Report (2016) Review Inspection
City of Marion RLAP
Permit No: WQ0019960
McDowell County
Dear Mr. Boyette:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
Enclosed please find a copy of the Annual Report Review Inspection Form from the inspection conducted on
6/28/2017. The facility was found to be in compliance with permit WQ0019960.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff
have any questions, please call me at 828-296-4500.
Sincerely,
� P
t,c�1
Beverly ce
Environmental Senior Specialist
Enclosure: Inspection Report
cc: Dennis Key, ORC
MSC 1617-Central Files -Basement
' vililee FiIN
I
G:\WR\WQ\McDowell\Wastewater\Non-discharge\City of Marion\City of Marion Land Application Class B\CEI.06.28.17.2016 AR Review.doex
State of North Carolina I Environmental Quality I Water Resources
2090 U.S. Highway 70 Swannanoa, NC 28778
828 296 4500

Compliance Inspection Report
Permit: WQ0019960 Effective: _ 08/01/16 Expiration: 07/31/21 Owner: City of Marion
SOC: Effective: Expiration: Facility: City of Marion RLAP
County: McDowell 3982 Hwy 226 S
Region: Asheville
Marion NC 28752
Contact Person: J Robert Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
System Classifications: LA,
PrimaryORC: Dennis Key Certification: 15704 Phone: [phone]
Secondary ORC(s):
OnSite Representative(s):
24 hour contact name Dennis Key 336-957-8909
Related Permits:
NC0031879 City of Marion - Corpening Creek WWTP
Inspection Date: 06/28/2017 Entry Time: 09:OOAM Exit Time: 11:OOAM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
A
Reason for Inspection: Routine Inspection Type: Annual Report Review
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant Not Compliant
Question Areas: \
Miscellaneous Questions Record Keeping Pathogen and Vector Attraction
(See attachment summary)
I
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 06/28/2017 Inspection Type: Annual Report Review Reason for visit: Routine
Inspection Summary:
The Annual Report Review was conducted by Beverly Price of the Asheville Regional Office.
35.13 Dry tons of residuals were land applied in 2016 to 4 permitted fields (Mario DeLuca #K1 & K2; John Fisher # F3 & F4).
Metals/nutrients analyses were conducted as required by the permit. Heavy metals were within ceiling concentration limits.
The TCLP analysis was not conducted in 2016; it is required once per permit cycle. The Ignitability, Corrosivity, Reactivity
analyses were conducted in 2016 and appear to have met regulatory limits.
Metals and PAN loading rates appeared to be calculated correctly and within permit limits.
Pathogen Reduction was accomplished using Alternative 1 (Fecal Coliform Density). Vector Attraction Reduction (VAR)
was accomplished using the Specific Oxygen Uptake Rate (SOUR). Calculations for pathogen and VAR appear to have
been done correctly.
A Standard Soil Fertility Analysis was conducted for each field receiving residuals. All 4 fields had pH <6; those fields had
lime applications in December 2016. Exchangeable Sodium Percentage (ESP) was <15% for all fields.
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 06/26/2017 Inspection Type Annual. Report.Review ., , Reason for Visit: " Routine
Tvpe Yes No NA NE
Distribution and Marketing ❑.
Land Application
Record Keeping
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?
Comment: Nutrient/metals results are for 2016.
TCLP not sampled in 2016 - requirement is.once per permit cycle.
Pathogen and Vector Attraction
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
Yes No NA NE
El ❑®❑
❑ ❑ E ❑
❑❑■❑
❑❑0R
❑ ❑ ❑
❑ N ❑ ❑
®❑ ❑ ❑
❑ E ❑ ❑
❑"❑ ❑
❑ ❑ ❑
❑ ❑ ❑
❑ ❑ ❑
❑ ❑ N ❑
❑ ❑ ❑
❑❑❑■
❑ ❑ ❑
❑ ❑ ❑ N
❑❑❑0
1111 ❑
❑■❑❑
Yes No NA NE
■❑❑❑
❑ ❑ ❑
❑❑■❑
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 06/28/2017 Inspection Type: Annual Report Review Reason for Visit: Routine
d. Salmonella (Class A, all test must be < 3MPN/4 gram day) ❑ ❑ N ❑
e. Time/Temp on: ❑ ❑ 0 ❑
Digester (MCRT) ❑
Compost ❑
Class A lime stabilization ❑
f. Volatile Solids Calculations ❑ ❑ 0 ❑
g. Bench -top Aerobic/Anaerobic digestion results ❑ ❑ N.❑
Comment:
Page: 4

Water Resources
ENVIRONMENTAL QUALITY
May 3, 2016
J. Robert Boyette
City of Marion
PO Drawer 700
Marion, NC 28752
SUBJECT: Annual Report Review (2015) Inspection
City of Marion RLAP
Permit No: WQ0019960
McDowell County
Dear Mr. Boyette:
PAT MCCRORY
1 L ,v Governor
DONALD R. VAN DER VAART
Secretary
S. JAY ZIMMERMAN .
Director.
Enclosed please find a copy of the Annual Report (AR) Inspection Form from the inspection conducted on 3/15/2016. The facility
was found to be in compliance with permit WQ0019960.
Please recalculate and resubmit the Field Summary Form for field K-2 as the acreage has decreased. The Form should be submitted
toe
NC DEQ-Division of Water Resources
Information Processing Unit
1617 Mail Services Center
Raleigh NC 27699-1617
According to the AR, the Specific Oxygen Uptake Rate (SOUR) is used to verify Vector Attraction Reduction (VAR). The test results
for all seven SOUR tests were included. The SOUR chart/curve should also be submitted with the analyses. The SOUR chart/curve
can be found on our web site at hgp://deq.nc.gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/non-
discharge-permitting-unit/reporting-forms under Residuals Forms.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff have any questions,
please call me at 828-296-4685.
Sincerely,
z3v/l/pt
Beverly Price
Environmental Senior Specialist
Enc.
cc: Larry Carver, Wastewater Superintendent w/enclosure
Dennis Key, ORC, SSB w/enclosure
MSC 1617-Central Files -Basement
�she�tlleFsles. -
G:\WR\WQ\McDowell\Wastewater\Non-discharge\City of Marion\City of Marion Land Application Class B\CEI16 2015 AR Review.docx '
State of North Carolina I Environmental Quality I Water Resources
2090 U.S. Highway 70 Swannanoa, NC 28778
828 296 4500

Compliance Inspection Report
Permit: WQ0019960 Effective: 08/20/07 Expiration: 07/31/16 Owner: City of Marion
SOC: Effective: Expiration: Facility: City of Marion RLAP
County: McDowell 3982 Hwy226 S
Region: Asheville
Marion NC 28752
Contact Person: J Robert Boyette Title:: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Bdi 86. Turn left onto Hwy. 226 south.: WWTP is approximately 1/2 mile on the right.
System Classifications: LA,
Primary ORC: Dennis Key Certification: 16704 Phone: [phone]
Secondary ORC(s):
David W Key 23629 336-957-7869
On -Site Representative(s):
24 hour contact name Dennis Key 336-957-8909
Related Permits:
Inspection Date: 03/16/2016 Entry Time: 01:OOPM Exit Time: 03:OOPM
Primary Inspector: Beverly Price gP Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Annual Report Review
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Pathogen and Vector Attraction
(See attachment summary)
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 03115/2016 Inspection Type: Annual Report Review Reason for visit: Routine
Inspection Summary:
72.6 dry tons of residuals were land applied to 4 permitted fields (Ross R1, R2; DeLuca K1, K2) during 2015. Soil samples
were taken on 11124/2015. All fields showed pH of >6.0. Zinc and Copper Indexes were <3000.
Pathogen & Vector Attraction Reduction was achieved using fecal coliform density and the SOUR Test. The SOUR oxygen
curve should be submitted with the annual report.
Nutrient/metals/TCLP analyses were conducted according to the permit requirements. PAN and field loading rates for each
metal appeared to be calculated correctly. Cummulative pollutant loading rates appeared to be within the permit limits.
However, the metal and PAN limits should be recalculated for Mario Deluca Field K2 as the acreage has been reduced.
Residuals were applied to fescue fields.
Page: 2

Permit WQ0019960 Owner - Facility: City of Marion
Inspection Date: 03/15/2016 Inspection Type : Annual Report Review
Reason for Visit: Routine
Pathogen and Vector Attraction
Yes No NA NE
a. Fecal coliform SM. 9221 E (Class A or B)
0 ❑ ❑
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)
❑ ❑ 0,13
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)
❑ ❑ 0'El
c. pH records for alkaline stabilization (Class B)
❑ ❑ 0 ❑
Temperature corrected
❑
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
❑ ❑ E ❑
e. Time/Temp on:
❑ ❑ On
Digester (MCRT)
❑
Compost
❑
Class A lime stabilization
❑
f. Volatile Solids Calculations
❑ ❑ 0 ❑
g. Bench -top Aerobic/Anaerobic digestion results
❑ ❑ 0 ❑
Comment:
Record Keeping
Yes No NA NE
Is GW monitoring being conducted, if required?
❑ ❑ N ❑
Are GW samples from all MWs sampled for all required parameters?
❑ ❑0 ❑
Are there any GW quality violations?
❑ ❑M ❑
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?
0 ❑ ❑ ❑
a. TCLP analysis?
❑ ❑ ❑
b. SSFA (Standard Soil Fertility Analysis)?
0 ❑ ❑ ❑
Are PAN balances being maintained?
E. ❑. ❑ ❑
Are PAN balances within permit limits?
❑ ❑ ❑
Has land application equipment been calibrated?
❑ ❑ ❑ E,
Are there pH records for alkaline stabilization?
❑ ❑ 0 ❑
Are there pH records for the land application site?
❑ ❑ ❑
Are nutrient/crop removal practices in place?
❑ ❑ ❑
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 03/16/2016 Inspection Type: Annual Report Review Reason for Visit- Routine
Record Keeping
Yes No NA NE
i
^ Do lab sheets support data reported on Residual Analysis Summary?
❑ ❑ ❑
s
Are hauling records available?
❑ ❑ ❑ ®
'
Are hauling records maintained and up-to-date?
❑ . ❑ ❑ ■
# Has permittee been free of public complaints in last 12 months?
❑ ❑ ❑ a
Has application occurred during Seasonal Restriction window?
❑ ❑ ❑
Comment: Applications were not outside seasonal restriction window.
Type
Yes No NA NE
Distribution and Marketing
❑
Land Application
'
11
"f t
3 n
1 B
yj
5
I
,i
3 ;
,i
I
7
ti
ri
Page: 4
=
3
t _
i
i

North Uarolina Department of Environmental Quality
Pat McCrory
Governor
October 9, 2015
J. Robert Boyette
City of Marion
Post Office Drawer 700
Marion, NC 28752
SUBJECT: Annual Report (2014) Review Inspection
City of Marion Residuals Land Application Program
Permit No: WQ0019960
McDowell County
Dear Mr. Boyette:
Donald R. van der Vaart
Secretary
Enclosed please find a copy of the Annual Report Inspection Form from the inspection conducted on 9/23/2015.
The facility was found to be in compliance with permit WQ0019960.
An issue of concern is the soils report for field K2 (Mario Deluca). The result for copper is listed as "very high".
It is recommended that this field be re -sampled to determine the copper "Index" and verify this result. Typically,
`when the copper "Index" reaches 3000 the field should be removed from the program.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff
have any questions, please call me at 828-296-4685.
Sincerely,
Beverly Price
Environmental Senior Specialist
Enc.
cc: Dennis Key, ORC SSB w/enclosure
MSC 1617-Central Files -Basement
Tss e--Alzl,- File
gor
G:\WR\WQ\McDowell\Wastewater\Non-discharge\City of Marion\City of Marion Land Application Class B\CEI15 2014 AR Review.docx
North Carolina Division of Water Resources — Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, N.C. 28778
Phone [phone]
FAX [phone]
Internet: http://portal.ncdenr.org/web/wq/
An -Equal Opportunity/Affirmative Action Employer

Cof''tl oliance Inspection Report
Permit: WQ0019960 Effective: 08/20/07 "Expiration: -' 07/31/16 Owner: City of Marion
SOC: Effective: Expiration: Facility: City of Marion Residuals Land Application Program
County: McDowell PO Drawer 700
Region: Asheville
Marion NC 28752 '
Contact Person: Robert J Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East.to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
System Classifications: LA,
Primary ORC: Dennis Key Certification:' 15704 Phone: [phone]
Secondary ORC(s):
David W Key 23629 336-957-7869
On -Site Representative(s):
24 hour contact name Dennis Key 336-957-8909
Related Permits:
Inspection Date: 09/23/2015 Entry Time: 08:OOAM Exit Time: 09:30AM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: ---Routine --- - - - -inspection-Type:- Annual Report Review
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant F1 Not Compliant
Question Areas:
Miscellaneous Questions Treatment Pathogen and Vector Attraction
(See'attachment summary)
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/2312015 Inspection Type: Annual Report Review Reason for Visit: Routine
Inspection Summary:
117.23 dry tons of residuals were land applied to 6 permitted fields in 2014. TCLP is required once per permit cycle. The
metals and nutrients analyses were conducted as required by the permit. Metals ceiling concentration limits were met.
Field F4 had a pH of 5.9. The Field Summary Form did not show an application of lime.
Field R1 had a pH of 5.9. The Field Summary Form did show an application of 2000 Ibs/ac in October 2014.
Field R2 had a pH of 5.6. The field Summary Form did show an application of 2000 Ibs/ac in October 2014.
The residuals pH was 6.6.
Soils Report:
Field K2 showed a Copper result of Very High.
It is recommended that this field be re -sampled to determine the 'Index" and verify if the copper result is accurate.
Typically, when the Copper Index reaches 3000 the field should be removed from the program.
Page: 2

permit WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/23/2015 Inspection Type: Annual Report Review
Reason for Visit: Routine
Tvpe
Yes No NA NE
Distribution and Marketing
❑
Land Application
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)
❑ 1:10 ❑
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)
❑ ❑ E ❑
c. pH records for alkaline stabilization (Class B)
❑ ❑ N ❑
Temperature corrected
❑
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
❑ ❑ ❑
e. Time/Temp on:
❑ ❑ N ❑
Digester (MCRT)
❑
Compost
❑
Class A lime stabilization
❑
f. Volatile Solids Calculations
❑ ❑ 0 ❑
g. Bench -top Aerobic/Anaerobic digestion results
❑ ❑ 0 ❑
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:
I
Page: 3

AA' } `
r�- 0 L
RCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
December 22, 2014
Robert J. Boyette, City Manager
City of Marion
PO Drawer 700
Marion, NC 28752.
SUBJECT: Compliance Evaluation Inspection (Land Application)
City of Marion Residuals Land Application Program
Permit No: WQ0019960
McDowell County
Dear Mr. Boyette:
John E. Skvarla, III
Secretary
Enclosed please find a copy of the Compliance Evaluation Inspection Form from the inspection conducted on
12/3/2014. The facility was found to be in compliance with permit WQ0019960.
The Mario DeLuca Field #K-2 now has a house as well as a vineyard. The permit should be modified to reflect
the reduction in acreage for this field.
Please refer to the enclosed inspection report for additional observations and comments. The assistance of Mr.
David Key was appreciated during the inspection. If you or your staff have any questions, please call me at
[phone]..
Sincerely,
3/,"4P/"'�
Beverly Price
Environmental Specialist
Enc.
cc: David Key, ORC Southern Soil Builders, Inc.
WQ Central Files
�Q��As dvi�hle�F1'es
G:\WR\WQ\McDowell\Wastewater\Non-discharge\City of Marion\City of Marion Land Application Class B\WQ0019960CEI14LA.doc
Water Quality Regional Operations — Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, North Carolina 28778
Phone: [phone] FAX: [phone]
Internet: http://portal.ncdenr.org/web/wq
An Equal Opportunity \Affirmative Action Employer

Compliance Inspection Resort
Permit: WQ0019960 Effective: 08/20/07 Expiration: 07/31/16 Owner: City of Marion
SOC: Effective: Expiration: Facility: City of Marion Residuals Land Application Program
County: McDowell PO Drawer 700
Region.. Asheville
Marion NC 28752
Contact Person: Robert J Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
System Classifications: LA,
Primary ORC: David W Key Certification: 23629 Phone: [phone]
Secondary ORC(s):
Dennis Key 15704 336-957-8909
On -Site Representative(s):
24 hour contact name Dennis Key
On -site representative David W Key
Related Permits:
Inspection Date: 12/03/2014 Entry Time: 12:OOPM Exit Time: 01:30PM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Land Application Site Transport
(See attachment summary)
Page: 1

permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 12/03/2014 - Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Land Application occurred on Deluca Field #K1 & #K2.
Fields were flagged.
Field #K2 now has a house and a vinyard. The permit should be modified to reflect the decrease in allowable acreage on
Field #K2.
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 12/03/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type
Distribution and Marketing
Land Application
Transport
Is a copy of the permit in the transport vehicle?
Is a copy of the spill control plan in the vehicle?
Is the spill control plan satisfactory?
Does.transport vehicle appear to be maintained?
Comment:
Land Application Site
Is a copy of the permit on -site during application events?
Is the application site in overall good condition?
Is the site free of runoff/ponding?
If present, is the application equipment in good operating condition?
Are buffers being maintained?
Are limiting slopes buffered?
10% for surface application
18% for subsurface application
Are there access restrictions and/or signs?
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
Is the water table greater than 173' bls.
Is application occurring at the time of the inspection?
Comment: No public water in the area.
Yes No NA NE
Yes No •NA NE
❑ ❑ ❑
■❑❑❑
■❑❑❑
■❑❑❑
Yes No NA NE
❑ ❑ ❑
❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
■❑❑❑
❑ ❑ ❑
❑ ❑ ❑
❑ ❑ E ❑
❑❑■❑
❑❑■❑
❑ M ❑ ❑
❑ ❑ ❑
■❑❑❑
❑ ❑ ❑
■❑❑❑
Page: 3

Permit: WQ0019960
SOC:
County: McDowell
Region: Asheville
Compliance Inspection Report
Effective: 08/20/07 Expiration: 07/31/16 owner: City of Marion
Effective: Expiration: Facility: City of Marion Residuals Land Application Program
PO Drawer700
Marion NC 28752
Contact Person: Robert J Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
System Classifications: LA,
Primary ORC: DA v i -Ke Certification: Phone:
Secondary ORC(s):
OnRSite Representative(s):
24 hour contact name David W Key 336-957-7869
Related Permits:
l
Inspection Date: 12/03/2014 Entry Time: 12:OOPM Exit Time: 01:30PM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant Not Compliant
Question Areas:
Miscellaneous Questions Land Application Site Transport
(See attachment summary)
r, pa,(r e
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 12/03/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 12/03/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Transport ��% (�c�- Yes No NA NE
Is a copy of the permit in the transport vehicle? ✓ ❑ ❑ ❑ .
Is a copy of the spill control plan in the vehicle? [] ❑ ❑ ❑
Is the spill control plan satisfactory? ✓ / [� ❑ ❑ ❑
Does transport vehicle appear to be maintained? Y ❑ ❑ ❑
Comment
Land Application Site
Yes No NA NE
Is a copy of the permit on -site during application events?
1 ❑ ❑ ❑
Is the application site in overall good condition?
❑ ❑ ❑
Is the site free of runoff/ponding?
�!] ❑ ❑ ❑
If present, is the application equipment in good operating condition?
01 ❑ ❑ ❑
Are buffers being maintained?
❑ ❑ ❑
Are limiting slopes buffered?
10% for surface application
[ ] ❑ ❑ ❑
18% for subsurface application
❑ ❑ ❑
Are there access restrictions and/or signs?]
❑ ❑ ❑
Is the application site free of odors or vectors?
❑ ❑ ❑
Have performance requirements for application method been met?
For injection?
❑ ❑ 0 ❑
For incorporation?
❑ ❑ EP ❑
Does permit require monitoring wells?
❑ ❑ ❑
Have required MWs been installed?
❑ ❑ [ ❑
Are MWs properly located w/ respect to RB and CB?
❑ ❑ ❑
Are MWs properly constructed (including screened interval)?
❑ ❑ [V ❑
Is the surrounding area served by public water?
❑ Em ❑ ❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted? 4f li
ru ❑ ❑ ❑
Are soil types consistent w/ Soil Scientist reportlevaluation?
❑ ❑
Is the water table greater than V/3' bls.
❑ ❑ ❑
Is application occurring at the time of the inspection?
EA ❑ ❑ ❑
Comment:
Page: 3

f7z'cW �a- kp S ;�. 46t,,ge,

�T � :�
M
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
November 21, 2014
Mr. Zach Key
Southern Soil Builders, Inc.
958 Hoots Road
Roaring River, NC 28669
SUBJECT: Map Requirements for Residuals Land Application
Southern Soil Builders, Inc.
Dear Mr. Key:
John E. Skvarla, III
Secretary
DEC - 1 2014
WaterauafityReglonal bperatlons
Recent permitting application packages that your company has submitted to the Division on behalf of
your clients have contained residuals land application site buffer maps that do not meet minimum
requirements established in North Carolina Administrative Code 15A NCAC 02T .1104. Without
adequate maps, the permitting process is delayed until a complete application can be submitted. It is
my hope that this letter will help clarify what is required as part of the application and provide you
with the tools you need to serve your clients.
Below are the minimum mapping requirements that shall be included on non -dedicated residuals land
application site maps. NC Administrative Code 02T .1104(c)(1) requires that Land Application Site.
Buffer Maps shall include:
(A) "a scaled may of the land application site, showing all related structures and fences
within the land application area;
(B) the location of all wells, streams (ephemeral, intermittent, and perennial), springs, lakes,
ponds, and other surface drainage features within 500 feet of the land application area
and setbacks as required by Rule .1108 of this section;
(C) and property boundaries within 500 feet of the land application site. "
In the future, please ensure that site buffer maps contain the above listed minimum requirements.
Specifically, maps must, be drawn utilizing an appropriate scale (e.g. scale no greater than
1 inch = 660 feet) that will cover the objective of the maps (i.e. maps that are legible, with the ability
to see setback details). Also, map components (e.g. buffers) added on top of the base map layer (i.e.
aerial photo) must be drawn to scale.
In an effort to provide clarification and promote consistency among permitted residuals land
application facilities the Division created the "Map Guidance for Residuals Land Application Fields
(Non -Dedicated)" document dated June 9, 2011. A copy of this document is enclosed for your
Non -Discharge Permitting Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Phone: [phone] Internet: htto://i)oital.ncdenr.om/web/wq
An Equal Opportunity 1 Affirmative Action Employer — Made in part with recycled paper

review. This document contains additional information which will assist Applicants in preparing
complete submittals. Please review this document in detail.
The Division appreciates your prompt attention to the above listed map requirements. Failure to
submit complete maps in the future will result in delayed permit issuance, and may result in the return
of the application packages as incomplete. If you have any questions concerning this letter, please
contact me at 919 807-6458, or by email at [e-mail].
Sincerely,
gq'e
Jon sgaard, Supervisor
a u... <., �,.,. •�a,.f.,..tt Non -Discharge Permitting Unit
Division of Water Resources
enc.: Map Guidance for Residuals Land Application Fields (Non -dedicated) dated June 9, 2011
cc: Mr. Michael M. Brandt, Town Manager — Town of Mayodan, 210 West Main Street, Mayodan, NC 27027(with enc)
ADO — DWR, UY.a er Quality Regional Operations Section (without enc.)
MRO — DWR, Water Quality Regional Operations Section (without enc.)
WSRO — DWR, Water Quality Regional Operations Section (without enc.)
Page 2 of 2

ALT? a L- "
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
September 23, 2014
J. Robert Boyette, City Manager
City of Marion
PO Box 700
Marion, NC 28752
SUBJECT: Compliance Evaluation Inspection (Facility)
City of Marion Residuals Land Application Program
Permit No: WQ0019960
McDowell County
Dear Mr. Boyette:
John E. Skvarla, III
Secretary
Enclosed please find a copy of the Compliance Evaluation Inspection Form from the inspection that I conducted
on 9/17/2014. The facility was found to be in compliance with permit WQ0019960.
Please refer to the enclosed inspection report for additional observations and comments. The assistance of Mr.
Larry Carver was greatly appreciated during the inspection. If you or your staff have any questions, please call
me at [phone].
Sincerely,
Beverly Price
Environmental Specialist .
Enc.
cc: Larry Carver, WWTP ORC
Q�A�Nshev�illlFles,:
WQ Central Files
G:\WR\WQ\McDowell\Wastewater\Non-discharge\City of Marion\City of Marion Land Application Class B\WQ0019960CEI14 Facility
Inspection.doc
Water Quality Regional Operations —Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, North Carolina 28778
Phone: 828-296A500 FAX: [phone]
Internet: http://portal.ncdenr.orgAveb/wq
An Equal Opportunity \ Affirmative Action Employer

Compliance Inspection Resort
Permit: WQ0019960 Effective: 08/20/07 Expiration: 07/31/16 owner: City of Marion
SOC: Effective: Expiration: Facility: City of Marion Residuals Land Application Program
County: McDowell PO Drawer 700
Region: Asheville
Marion NC 28752
Contact Person: Robert J Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
System Classifications: LA,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name Larry Dean Carver, 828-652-8843
On -site representative Larry Dean Carver 828-652-8843
Related Permits:
Inspection Date: 09/17/2014 EntryTime: 10:15AM Exit Time: 10:30AM
Primary Inspector: Beverly Price Phone: [phone]
Secondary. Ins pector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Sampling
(See attachment summary)
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/17/2014 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
This inspection included a tour of the residuals facilities. The facilities consist of a 750,000 gallon digester. The digester
was approximately 1/2 full. The digester fill station area drains back to the head of the VWVfP. There is a stormwater drain
in close proximity to the fill station which is temporarily covered during times when loading is occurring. PathogenNAR is
verified through fecal coliform sampling and SOUR tests.
The last land application occurred in May of 2014.
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/1712014 Inspection Type: Compliance Evaluation Reason for Visit: Routine -
Type Yes No NA NE
Distribution and Marketing ❑
Land Application
Record Keeping
Yes No NA NE
Is GW monitoring being conducted, if required?
❑ ❑ 0❑
Are GW samples from all MWs sampled for all required parameters?
❑ ❑ 0 ❑
Are there any GW quality violations?
❑ ❑ E ❑
Is GW-59A certification form completed for facility?
❑ ❑ N ❑
Is a copy of current permit on -site?
❑ ❑ ❑
Are current metals and nutrient analysis available?
❑ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
N ❑ ❑ ❑ .
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?
❑ ❑ 0 ❑
Are there pH records for alkaline stabilization?
❑ ❑ E ❑
Are there pH records for the land application site?
❑ ❑ ❑
Are nutrienticrop removal practices in place?
❑ ❑ ❑
Do lab sheets support data reported on Residual Analysis Summary?
❑ ❑ ❑
Are hauling records available?
❑ ❑ ❑ 0
Are hauling records maintained and up-to-date?
❑ ❑ ❑
•# Has permittee been free of public complaints in last 12 months?
❑ ❑ ❑ 0
Has application occurred during Seasonal Restriction window?
❑ ❑ 0 ❑
Comment:
Sampling Yes No NA NE
Describe sampling:
Samples for metals/nutrients/fecal coliform are collected from the digester while the contents are mixed.
Is sampling adequate? 0 11110
`
Is sampling representative? 0 ❑ ❑ ❑
Comment:
Page: 3

Compliance Inspection Report
Permit: WQ0019960 Effective: 08/20/07 Expiration: 07/31/16 owner: City of Marion
SOC: Effective: Expiration: Facility: City of Marion Residuals Land Application Program
County: McDowell PO Drawer 700
Region: Asheville
Marion NC 28752
Contact Person: Robert J Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
On -site representative
Related Permits:
a 1(7 /1
Inspection Date: 'tTfG4 6
Primary Inspector: Beverly Price
Secondary Inspector(s):
Larry Dean Carver
Larry Dean Carver
Entry Time: uO� 1 !� Exit Time: (0:3 d
Reason for Inspection: Routine
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping
828-652-8843
828-652-8843
Phone: [phone]
Inspection Type: Compliance Evaluation
(See attachment summary)
rv,,O,l ( �2./ a CD( Ll _ l,A_S4
S
/ 5
E Sampling
Page: 1

Permit: WQ0019960
Inspection Date: 07/04/1976
Inspection Summary:
l3/0W�r�
Owner - Facility: City of Marion
Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Page: 2

M
Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 07/04/1976 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Record Keeping
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?
Comment:
Sampling
Describe sampling:
Is sampling adequate?
Is sampling representative?
Comment:
�JILI l��r
t,
t(
G,-�b #-- l
4�
v rf
Yes No NA NE
❑❑L]❑
❑ ❑ LV ❑
❑❑Ep❑
❑❑❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
M ❑ ❑ ❑
J❑❑❑
❑ ❑ ❑ ❑
❑❑❑�J
Yes No NA NE
SaVVP ("_')'
0cos
V
Page: 3

FILE
©i�
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
July 15, 2014
J. Robert Boyette, Town Manager
City of Marion
Post Office Drawer 700
Marion, NC 28752
SUBJECT: Compliance Evaluation Inspection
2013 Annual Report Review
City of Marion Residuals Land Application Program
Permit No: WQ0019960
McDowell County
Dear Mr. Boyette:
John E. Skvarla, III
Secretary
Enclosed please find a copy of the Compliance Evaluation Inspection Form from the inspection completed on
June 30, 2014. The facility was found to be in compliance with permit WQ0019960.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff
have any questions, please call me at(828) 296-4685.
Sincerely,
Beverly Price
Environmental Specialist
Enc.
cc: Dennis Key, ORC SSB
WQ Central Files
A h�vitltl ides
G:\WR\WQ\McDowell\Wastewater\Non-discharge\City of Marion\City of Marion Land Application Class B\WQ0019960CEI14 2013 Annual
Report Review.doc
Water Quality Regional Operations —Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, North Carolina 28778
Phone: [phone] FAX: [phone]
Internet: hfp://portal.ncdenr.org/webtwq
An Equal Opportunity 1 Affirmative Action Employer

Compliance Inspection Repori�
Permit: WQ0019960 Effective: 08/20/07 Expiration: 07/31/16 Owner: City of Marion
SOC: Effective: Expiration: Facility: City of Marion Residuals Land Application Program
County: McDowell PO Drawer 700
Region: Asheville
Marion NC 28752
Contact Person: Robert J Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Exit 86. Turn left onto Hwy. 226 south. VWVTP is approximately 1/2 mile on the right.
System Classifications: LA,
Primary ORC: Dennis Key Certification: 15704 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name Larry Dean Carver
Related Permits:
Inspection Date: 06/30/2014 Entry Time: 03:OOPM
Primary Inspector: Beverly Price
Secondary nspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ® Compliant Not Compliant
Question Areas:
® Miscellaneous Questions 10 Record Keeping
(See attachment summary)
Exit Time: 03:45PM
828-652-8843
Phone: [phone]
Inspection Type: Compliance Evaluation
N Pathogen and Vector Attraction
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 06/30/2014 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
This inspection consisted of a review of the 2013 Annual Report.
77.04 dry tons of residuals were land applied in 2013.
Fields with pH <6.0 were limed.
Metals/Nutrient/pathogen/vector attraction reduction analyses were conducted according to permit conditions.
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 06/30/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type s 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?
❑ ❑ ❑ E
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)?
M ❑ ❑ ❑
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?
N ❑ ❑ ❑
Are nutrient/crop removal practices in place?
❑ ❑ ❑ 0
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?
❑ ❑ ® ❑
Comment:
Pathogen and Vector Attraction Yes No NA NE
a. Fecal coliform SM 9221 E (Class A or B) E ❑ ❑ ❑
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

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 06/30/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
e. Time/Temp on: ❑ ❑ 1111
Digester (MCRT) A ❑
Compost ❑
Class A lime stabilization ❑
f. Volatile Solids Calculations ❑ ❑ ® ❑
g. Bench -top Aerobic/Anaerobic digestion results ❑ ❑ ® ❑
Comment:
Page: 4

MCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
September 30, 2013
Robert J. Boyette, City Manager
City of Marion
Post Office Drawer 700
Marion, NC 28752
SUBJECT: August 28, 2013
Compliance Evaluation Inspection
Residuals Land Application Program
Permit No: WQ0019960
McDowell County
Dear Mr. Boyette:
Enclosed please find a copy of the Compliance Evaluation Inspection Form from the
inspection conducted on August 28, 2013. The facility was found to be in Compliance with
permit WQ0019960.
The inspection included a review of the 2012 Annual Report (AR). The following
parameters were missing from the TCLP Analysis: 2,4-D and 2,4,5-TP (Silvex). Please submit
the missing data to the Asheville Regional Office within 10 days of receipt of this letter.
Please refer to the enclosed inspection report (Inspection Summary Page 2) for
additional observations and comments. The assistance of Mr. Larry Carver and Mr. Dennis Key
was greatly appreciated during the inspection. If you or your staff have any questions, please
call me at [phone].
Sincerely,
A)ILI"
Beverly Price
Environmental Specialist
Enclosure
cc: Zack Key, SSB
APS Central Files
W,'.Q�AshEville-Files
WATER QUALITY SECTION
North Carolina Division of Water Resources —Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, N.C. 28778
Phone [phone]
FAX [phone]
Internet: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer

Compliance Inspection Report
Permit: WQ0019960 Effective: 08/20/07 Expiration: 07/31/16 Owner: City of Marion
SOC: Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
County: McDowell PO Drawer 700
Region: Asheville
Marion NC 28752
Contact Person: Robert J Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
System Classifications: LA,
Primary ORC: Dennis Key Certification: 15704 Phone: [phone]
Secondary ORC(s):
David W Key Certification: 23629 Phone: [phone]
On -Site Representative(s):
24 hour contact name David W Key Phone:
On -site representative Larry Dean Carver Phone:
On -site representative David W Key Phone:
Related Permits:
Inspection Date: 08/2812013 Entry Time: 01:00 PM Exit Time: 02:30 PM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: W Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment 0 Sampling
Land Application Site Pathogen and Vector Transport
Attraction
(See attachment summary)
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 08/28/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The inspection included a review of the 2012 Annual Report (AR) and a site visit to land application fields.
2012 AR Issue: Parameters missing from the TCLP: 2.4-D and 2,4,5-TP(Silvex) These parameters need to be submitted.
Received complete data sets for SOUR Test from Marion WWTP lab.
Application was occurring on the Mario Deluca Fields. Residuals were scheduled to be applied later in the day to the
Wayne Ross Fields. Signs in place; field/buffers were flagged; no runoff observed; cover crop looked good.
The acreage taken up by the vineyard should be removed from the permit. This is approximately 2.5 acresfrom Field K-2.
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 08/28/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type Yes No NA NE
Distribution and Marketing ❑
Land Application
Record Keeping
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?
Comment:
Pathogen and Vector Attraction
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)
Yes No NA NE
❑ Cl n ❑
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❑ ❑ W ❑
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Yes No
NA
NE
t
❑❑❑
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 08/28/2013 Inspection Type: Compliance Evaluation
Reason for Visit:
Routine
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
n
b. pH records for alkaline stabilization (Class A)
n
n
®
n
c. pH records for alkaline stabilization (Class B)
n
n
w
n
Temperature corrected
❑
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
❑
n
M
n
e. Time/Temp on:
❑
n
®
n
Digester (MCRT)
n
Compost
❑
Class A lime stabilization
f. Volatile Solids Calculations
❑
g. Bench -top Aerobic/Anaerobic digestion results
n
n
if
Q
Comment:
4a,,..4... —6.
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Comment:
Sampling
Describe sampling:
SOUR Test - effluent from the aeration basin before discharging to the secondary clarifiers. Fecal, metals
and nutrient samples are from the digesters.
Is sampling adequate?
Is sampling representative?
Comment:
'r— —.4
Is a copy of the permit in the transport vehicle?
Yes No NA NE
n
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n
n
Yes
No
NA
NE
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®nnn
Yes
No
NA
NE
®nn❑
Page: 4

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 08/28/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Is a copy of the spill control plan in the vehicle? ❑ ❑ ❑
Is the spill control plan satisfactory? ( ❑ ❑ ❑
Does transport vehicle appear to be maintained? ❑ ❑ ❑
Comment:
Land Application Site
Is a copy of the permit on -site during application events?
Is the application site in overall good condition?
Is the site free of runoff/ponding?
If present, is the application equipment in good operating condition?
Are buffers being maintained?
Are limiting slopes buffered?
10% for surface application
18% for subsurface application
Are there access restrictions and/or signs?
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
Is the water table greater than 173' bls.
Is application occurring at the time of the inspection?
Comment: No public water and no monitoring wells.
Yes No NA NE
❑ E ❑ ❑
im ❑ ❑ ❑
El❑❑0
❑ ❑ ❑
®❑❑❑
Page: 5

"JA FRI 11:42 AM MARIO UPT
FAX:'-"'1591943 P.001/003
I
&M WWTP
Mcgit
P. Box
Marion, NC 28752
...... ....
fill cs _.. ___ g rans
To: Bev Price Fax: [phone]
From: Larry Carver Date: 10/4/2013
Re: Analysis data Pages: 3
M.
0 urgent 0 For Review 0 Please Comment 0 Please Reply [j Pleaw Recycle
-
2evhere isthe bftyou .r9que5W Ifyou have arlyClUeStwe me a call $2602-8W or 82SA604M
questions pleasegi
. . . . . . . . . . . . . w * # . . . . . . .

OCT-04-2013 FRI 11:42 AM MARL( WPT
FAX: 591943 P. 00',z/
A&w-1 o f'J
-G eP
Analytical Environmental Services, Inc. Date: 24 Feb-12
CLIENT:
Prism Laboratories
CIient sample ID: 2020345-01
Lab Order:
1202F57
Tag Number: 2020345-01
Project:
2020345
Collection bate: 2/14/2012 9,53,00 AM
Lab ID:
1202F57-001A
Matrix: SOLID
Analyses
Result Quai
!VIOL Limit Chits Rstcl;jA DF Date Analyzed
HERBICIDES.TCLP SWI31118151A
($W3510C) Analyst., !AFC
2,4.&TP (Siivex)
BRL
0.044 0.20 m91L 168W5 1 2/2212012 5:25:00 PM
2.4-D
BRL
o.063 020 MglL 158035 1 2J22/2012 6:25:00 PM
Surr. DCAA
110
0 47.1.151 %RBC 158035 1 7Jza12012 5:25:00 PM
Qualificta: Va1w extoods Maximvut Contaminant Lovol < 1AU than Rastitt value
> Greater than Result value a Analyze detected in the associated Method Blank
BRL Below Repotting Litnit E Estimated value above quaariratioa range
H Holding times for preparation or analysts oxecoded 7 Estimated value detected below Repordng Limir
N An4lyto cot NF L,AC certified Rpt Jam It cper[iug Limit Page 1 of 1
S Spike Recovery outside limits due to matrix
P890 3 of 6
Page 19 of 25

Analytical Environmental Services, Inc Date; 24-Feb-12
Client: Prism Laboratories ANALYTICAL QC SUMMARY REPORT
Project NAMC; 2020345
Rror]carder: 1202FS7
Ilokehll); 168036
Smnple ID: NIE-15SO35
Client I€):
Units: r11gJL
Prep Date: 02121J2012
Ruu No: 215757
SwupleType: h113LK
TesrCode: HeRBrCIDF3 TCLV SR'IMISASIA
BatchID; 158035
Analysis Dale: 02l2212012
SegNo: 4511676
Analyte
Result RPT Limit SPK value SPK Ref Val
°%REC Lou Limit
Higb Limit RPD Ref Vat %RPD
RYD Limit Qua]
2,4,5-TP (Siluex)
BRL
9.20
0
0
0
0
a
0
fl 0
2,4-D
BRE-
0.20
0
0
fl
0
a
0
0 a
Surr: DCAA
0.4446
0
0.5
0
89_1
47.1
151
0
0 0
Sample ID; LCS-ISS035
Client ID:
Units: wglL
Prep Date. 0MV1012
Run Na 215757
3ampleType: LCS
Testcode: I1BRB3C3pES,TcLp S1,Y1311talsIA
BatchtD:158035
Analysis We: 0212I(2012
SegNo- 4511677
Aoa]yte
Resull RPT Limit SPK value SPKRefVal
a/.REC Low Limit
High Limit RPDRofVW %RPD
RPI)Limit Qoal
2,4,5-TP (SIvex)
2,4-D
Suar. DCAA
0.4547
0.20
0.5
a
' 90.9
61.8
129
0
0 0
0.4530
0.20
0.5
0
90.6
62.3
132
0
a 0
0.4984
0
0.5
0
99.7
47.1
151
0
0 0
San1p1e1D: 12021T57-001ARIS -
Client ID: 2020345-D1
UK&: mgtL
Prep Date: 0212112012
Ruat No: 215757
SwVleType: MS
TWCodc: HERBIC1o¢s,TCLP SWI311AISIA
BatchID: ISS035
Analysis Date. 02I=912
Seg No: 4511679
Analy(e
Result RPT Limit SPK value SPK Ref Val
%REC Lott Limit
digit Limit RPD Ref Val %RPD
RFD Limit Qua]
2,4,5-TP (Silvex) 0.5152 0.20 0.5 0 103 66.3 130 0 a 0
2,4 D 0.4664 0.20 0.5 0 93.3 66.4 135 0 0 0
Sun: DCAA d.5648 0 0.5 0 113 47.1 151 0 0 0
� 9u 6fe�s> > 67es¢rfn+�Rvu.t>,xlu: < Less shu Rauh wlue
4}
CQ BRL adow rracenp bait E Esliwlas. {vi`sr Wove gsantitrScn saigr)
(D
N 1 azemm:.d ♦due dcrard 6craw a.poift Linn M AaryLmIWKLAC"i sd
N Rpslrm Repa>tirg U-6t 5 Sple Rrcarery wlsidc li�mss due to msaix
I
B hns:51e d+aeled in>Ze fssodekd ecdw�blck
FC Iie�dins Om:s r>r pnper+lian¢a-iysisemceda
R ItPD easds limit da ao aravi%
Page 6 of 6

Comepliance Inspection Report
Permit: WO0019960 Effective: 08/20/07 Expiration: 07/31/16 Owner: City of Marion
SOC: Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
County: McDowell PO Drawer 700
Region: Asheville
Marion NC 28752
Contact Person: Robert J Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
System Classifications: LA,
Primary ORC: Dw Certification: Phone:
Secondary ORC(s): f
On -Site Representative(s): (4�-�
Related Permits:
Inspection Date: 08/2812013 Entry Time: 01:00 PM Exit Time: 02:30 PM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment Sampling
Land Application Site Pathogen and Vector ■ Transport
Attraction
(See attachment summary)
v�n�a'-d' \%/- a-!�� iA-C
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 08/28/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 08/28/2013 Inspection Type: Compliance Evaluation
Reason for Visit:
Routine
Record Keeping
Yes
No
NA NE
Is GW monitoring being conducted, if required?
❑
❑
0 ❑
Are GW samples from all MWs sampled for all required parameters?
❑
❑
❑
Are there any GW quality violations?
❑
❑
�Q
+-R y ❑
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? a �--� � �-� ��
J
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? Gv-A2.'—C!
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?
Comment:
Pathogen and Vector Attraction
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)
Yes No NA NE
0 ❑ ❑ ❑
❑,/ /t!�
4n ❑ El
❑❑Y❑
❑❑Y❑
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 08/28/2013 Inspection Type: Compliance Evaluation
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:
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Comment:
Sampling
Describe sampling: SOxj,I� 71 S
e-��.
Is sampling adequate?
Is sampling representative?����s
Comment:
Transport
Is a copy of the permit in the transport vehicle?
Is a copy of the spill control plan in the vehicle?
Is the spill control plan satisfactory?
Does transport vehicle appear to be maintained?
Comment:
Reason for Visit: Routine
n
nnt,n
n❑ ❑
o
nnMn
00TF1
Yes No NA NE
IS
n
n
n
n
n
n
Yes No NA NE
n n n n
n n n n
Yes No NA NE
Page: 4

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 08/28/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Land Application Site Yes No NA NE
Is a copy of the permit on -site during application events? !,� ❑ ❑ ❑
Is the application site in overall good condition?
Q ❑ ❑
❑ ❑ ❑
Is the site free of runoff/ponding?
If present, is the application equipment in good operating condition?
❑ ❑ ❑
Are buffers being maintained?
❑ ❑ ❑
Are limiting slopes buffered?
❑ ❑ ❑
10% for surface application
❑ ❑ )0 ❑
18% for subsurface application
Are there access restrictions and/or signs?
❑ ❑ ❑
Is the application site free of odors or vectors?
❑ ❑ ❑
Have performance requirements for application method been met?
For injection? ❑ ❑ ❑
For incorporation? ❑ El � ❑
Does permit require monitoring wells? In ❑ ❑
Have required MWs been installed? ❑ ❑ ❑
Are MWs properly located w/ respect to RB and CB? ❑ ❑ ❑
Are MWs properly constructed (including screened interval)? ❑ ❑ ❑
Is the surrounding area served by public water? ❑ T ❑ ❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted? ❑ ❑ ❑
Are soil types consistent w/ Soil Scientist report/evaluation? [� ❑ ❑ C1
Is the water table greater than 173' bls. ❑ ❑ ❑ 0
Is application occurring at the time of the inspection? ❑ ❑ ❑
Comment:
Mo'�- i o Palu.c_c.�' n e-l4 r
Page: 5

1 4i 8 5 m
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Thomas A. Reeder John E, Skvarla, III
Governor Acting Director Secretary
June 18, 2013
Robert Boyette, City Manager
City of Marion
Post Office Drawer 700
Marion, NC 28752
Subject: 2012 Annual Residuals Reports
Marion Water Treatment Plant
Permit No.WQ0031674
Marion Land Application of Residual Solids
Permit No.WQ0019960
Marion Surface Disposal Unit
WQ0003698
Dear Mr.Boyette:
The Asheville Regional Office has received a copy of your 2012 Annual Reports. We
have completed a preliminary review of the Reports. You will be contacted if any
additional information is needed.
Thank -you for your submittal.
Sincerely,
Beverly Price
Environmental Specialist
AQUIFER PROTECTION SECTION -
North Carolina Division of Water Quality — Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, N.C. 28778
Phone [phone]
FAX [phone]
Internet: h2o.enr.state. nc.us
An Equal Opportunity/Affirmative Action Employer

4;: -- E71"
V
NCDENR C 00 '! Poi
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Robert Boyette, City Manager
City of Marion
Post Office Drawer 700
Marion, NC 28752
Dear Mr.Boyette:
Division of Water Quality
Charles Wakild, P. E.
Director
December 10, 2012
Dee Freeman
Secretary
SUBJECT: November 16, 2012
Compliance Evaluation Inspection
City of Marion Land Application of Residual
Solids (503)
Permit No: WQ0019960
McDowell County
Enclosed please find a copy of the Compliance Evaluation Inspection Form from the
inspection conducted on November 16, 2012. The facility was found to be in Compliance with
permit WQ0019960.
The field #K-02, leased by Mario Deluca, now has a small vineyard. The permit should
be modified to reflect this reduction in acreage.
Please refer to the enclosed inspection report for additional observations and comments.
If you or your staff have any questions, please call me at [phone].
Sincerely,.
Beverly Price
Environmental Specialist
Enclosure
cc: David W Key, ORC SSB
APS Central Files
--AFS AAshevillei�F_i _es�
AQUIFER PROTECTION SECTION —Asheville Regional Office (ARO)
2090 U.S. 70 Highway, Swannanoa, NC 28778-8211
Phone: [phone] FAX: [phone]
Intemet: www.ncwaterouality.oM
An Equal Opportunity 1 Affirmative Action Employer
MithCarolina
Nodlll'ally

Compliance Inspection Report
Permit: WQ0019960 Effective: 08/20/07 Expiration: 07/31/16 Owner: City of Marion
SOC: Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
County: McDowell PO Drawer 700
Region: Asheville
Marion NC 28752
Contact Person: J Robert Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
System Classifications: LA, -
Primary ORC: David W Key Certification: 23629 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
24 hour contact name
On -site representative
Related Permits:
Inspection Date: 11/16/2012
Primary Inspector: Beverly Price
Secondary Inspector(s):
David W Key
Larry Dean Carver
David W Key
Entry Time: 09:30 AM Exit Time: 11:00 AM
Phone: [phone]
Phone: [phone]
Phone: [phone]
Phone: [phone]
Reason for Inspection: Follow-up Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ® Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions ® Land Application Site ® Pathogen and Vector ® Transport
Attraction
(See attachment summary)
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 11/16/2012 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Inspection Summary:
Residuals were applied to fields R-2 and K-1.
Residuals were applied to field K-2 on 11/15.
Acreage on field K-2 has been reduced due to installation of vinyard. Permit should be modified.
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 11/16/2012 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Type Yes No NA NE
Distribution and Marketing ❑
Land Application
Pathogen and !lector 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) ❑ ONO
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) ❑ ❑ E ❑
c. 'pH records for alkaline stabilization (Class B) ❑ ❑ E ❑
Temperature corrected ❑
d. Salmonella (Class A, all test must be < 3MPN/4 gram day) ❑ ❑ ® ❑
e. Time/Temp on: ❑ 0 N ❑
Digester (MCRT) ❑
Compost
Class A lime stabilization ❑
f. Volatile Solids Calculations Cl ❑ ® ❑
g. Bench -top Aerobic/Anaerobic digestion results ❑ ❑ ® ❑
Comment:
Transport
Yes
No
NA NE
Is a copy of the permit in the transport vehicle?
N
❑
❑ ❑
Is a copy of the spill control plan in the vehicle?
a
❑ ❑
Is the spill control plan satisfactory?
®❑
❑ ❑
Does transport vehicle appear to be maintained?
®❑
❑ ❑
Comment:
Land Application Site
Yes
No
NA NE
Is a copy,of the permit on -site during application events?
IN
❑
❑ ❑
Is the'application site in overall good condition?
M
❑
❑ ❑
Is the site free of runoff/ponding?
IN
❑ ❑
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 11/16/2012 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
If present, is the application equipment in good operating condition? n n n
Are buffers being maintained? n n n
Are limiting slopes buffered?
10% for surface application
18% for subsurface application
Are there access restrictions and/or signs?
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RIB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
Is the water table greater than 173' bls.
Is application occurring at the time of the inspection?
Comment: MW's not required.
Municiple water not avaliable in the area.
R❑nn
nnIN0
n n n
nnn
nnn
nn00
0 N 0 0
nn®n
nn®n
nnn
n@1nn
®nnn
®nnn
nnn®
Bnnn
Page: 4

Permit: WQ0019960
SOC:
County: McDowell
Region: Asheville
Compliance Inspection Report
Effective: 08/20/07 Expiration: 07/31/16 Owner: City of Marion
Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
PO Drawer 700
Marion NC 28752
Contact Person: J Robert Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
System Classifications: LA,
Primary ORC: David W Key Certification: 23629 Phone: [phone]
Secondary ORC(s): 7 '' S
On -Site Representative(s):
24 hour contact name Larry Dean Carver Phone: [phone]
Related Permits:
Inspection Date: 11/16/2012
Primary Inspector: Beverly Price
Secondary Inspector(s):
Entry Time: 09:30 AM Exit Time: 11:00 AM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions E Sampling Land Application Site Pathogen and Vector
Attraction
TransportAA
_
(See attachment summary)
CNa.wc 20 ss
ID
e.,
Lk/ 01 V"44- -� t\I 0
Page: 1
i
� c�
o ai ts��tF
S r Pam d
p� ��

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 11/16/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
�0 a-- , a P 0d�s
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 11/16/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Pathogen and Vector Attraction Yes No NA NE
a. Fecal coliform SM 9221 E (Class A or B) 1'9! ❑ ❑ ❑
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)
❑
❑ ❑
e. Time/Temp on:
❑
❑ ❑
Digester (MCRT)
❑
Compost
❑
Class A lime stabilization
❑
f. Volatile Solids Calculations
❑
❑ ❑
g. Bench -top Aerobic/Anaerobic digestion results
❑
❑ P ❑
Comment:
Sampling
Yes
No NA NE
Describe sampJing:
Is pling adequate?
❑ ❑ ❑
❑
Jssmpling representative?
❑ ❑ ❑
❑
Comment:
Transport
Yes No NA
NE
Is a copy of the permit in the transport vehicle?
❑ ❑
❑
Is a copy of the spill control plan in the vehicle?
❑ ❑
❑
Is the spill control plan satisfactory?
❑ ❑
❑
Does transport vehicle appear to be maintained?
❑ ❑
❑
Comment:
Land Application Site
Yes No NA
NE
Is a copy of the permit on -site during application events?
g ❑ ❑
❑
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 11/16/2012 Inspection Type: Compliance Evaluation
Is the application site in overall good condition?
Is the site free of runoff/ponding?
If present, is the application equipment in good operating condition?
Are buffers being maintained?
Are limiting slopes buffered?
10% for surface application
18% for subsurface application
Are there access restrictions and/or signs? f:,-4-AC,'e ^ j
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
Is the water table greater than 173' bls.
Is application occurring at the time of the inspection?
Comment:
Reason for Visit: Routine
01000
❑ ❑ ❑
ft❑❑❑
1000
0❑❑❑
❑ ❑ ❑ ❑
0000
0❑❑❑
❑❑1i❑
❑❑G7i ❑
❑a00
❑❑fir❑
❑❑ ❑
❑❑00
❑,0❑❑
❑❑00
t❑❑❑
❑❑❑p
V 0 0 0
Page: 4

Price, Bev
From: Hardee, Ed
Sent: Monday, November 19, 2012 4:09 PM
To: Price, Bev
Subject: RE: Setback Waiver
Bev,
I do not believe there is any waiver for property line setbacks for residuals.
Ed Hardee
Aquifer Protection Section
Land Application Unit
1636 Mail Service Center
Raleigh, NC 27699-1636
Phone [phone]
DISCLAIMER: Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties unless the content is
exempt by statute or other regulation.
From: Price, Bev
Sent: Friday, November 16, 2012 3:43 PM
To: Hardee, Ed
Subject: Setback Waiver
Ed,
Can the property line setback be waived for residuals (Class B)? The only waiver I'm aware is for residences (400' to
100') not owned by the permittee. There are property boundary Waiver Forms for spray irrigation but not residuals.
Thanks,
Bev
Bev Price - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Aquifer Protection Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
1

A
lr&�ENR
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E.
Governor Director
Robert Boyette, City Manager
City of Marion
Post Office Drawer 700
Marion, NC 28752
August 27, 2012
i�, 11 L. cc��'��t"� E
Natural Resources
Dee Freeman
Secretary
SUBJECT: August 7, 2012
Compliance Evaluation Inspection
City of Marion Land Application of Residual
Solids (503)
Permit No: WQ0019960
McDowell County
Dear Mr.Boyette: '
Enclosed please find a copy of the Compliance Evaluation Inspection Form from the
inspection conducted on August 7, 2012. The facility was found to be in Compliance with permit
WQ0019960.
Please re -submit the Annual Field Summary Forms for the 2011 Annual Report. The
cumulative totals (lb/ac) for Zinc were incorrectly calculated. The Zinc result used in calculating
the Annual Heavy Metal Field Loadings (lb/ac) was 120 mg/kg rather than the correct result of
1020 mg/kg.
Please refer to the enclosed inspection report for additional observations and comments.
If you or your staff have any questions, please call me at [phone].
Sincerely, /
Beverly rice
Environmental Specialist
Enclosure
cc: Zack Key SSB 958 Hoots Road Roaring
APS Central Files
APSi,A'sheUilleFi1 s
AQUIFER PROTECTION SECTION —Asheville Regional Office (ARO)
2090 U.S. 70 Highway, Swannanoa, NC 28778-8211
Phone: [phone] \ FAX: [phone]
Internet: www.ncwaterguality.oM
An Equal Opportunity \ Affirmative Action Employer
River, NC 28669 w/enclosure
One
NorthCarolina
Nahmallff

Compliance Inspection Report
Permit: WQ0019960 Effective: 08/20/07 Expiration: 07/31/16 Owner: City of Marion
SOC: Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
County: McDowell PO Drawer 700
Region: Asheville
Marion NC 28752
Contact Person: J Robert Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
System Classifications: LA,
Primary ORC: Dennis Key Certification: 15704 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name Larry Dean Carver Phone: [phone]
On -site representative Larry Dean Carver Phone: [phone]
Related Permits:
Inspection Date: 08/07/2012 Entry Time: 09:30 AM Exit Time: 10:30 AM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions N Record Keeping Treatment ■ Pathogen and Vector
Attraction
(See attachment summary)
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 08/07/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Reminder: TCLP is required once per permit cycle.
Soils anayses will be collected this fall.
SOUR Test is used to verify VAR - hold time, final dissolved oxygen reading and % solids all ok for Spring 2012
application.
Spring 2012 applications occurred on fields R1, R2, F3, F4 and K1.
New digester has resulted in very low fecal coliform counts for pathogen reduction.
Reviewed 2011 Annual Report (AR) as part of this inspection.
2011 AR Issue: Zn cumulative totals(lb/ac) need to be re -calculated on the Annual Field Summary Forms as the wrong
result (120 mg/kg instead of 1020 mg/kg)was used when calculating the Annual Heavy Metal Field Loadings (lbs/ac).
The acreage for Field K2 should be reduced as part of that field is now in a vineyard. This will require a minor permit
modification.
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 08/07/2012 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Type
Yes
No NA NE
Distribution and Marketing
❑
Land Application
■
Record Keeping
Yes
No NA NE
Is GW monitoring being conducted, if required?
11110
❑
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?
■
Cl ❑ ❑
a. TCLP analysis?
❑
❑ N ❑
b. SSFA (Standard Soil Fertility Analysis)?
❑
❑ ■ ❑
Are PAN balances being maintained?
■
❑ ❑ Cl
Are PAN balances within permit limits?
■
❑ ❑ ❑
Has land application equipment been calibrated?
❑
❑ ❑ E
Are there pH records for alkaline stabilization?
❑
❑ ❑ E
Are there pH records for the land application site?
N.
❑ ❑ Cl
Are nutrient/crop removal practices in place?
❑
❑ ❑ ■
Do lab sheets support data reported on Residual Analysis Summary?
0
❑ ❑ ❑
Are hauling records available?
0
❑ ❑ ❑
Are hauling records maintained and up-to-date?
■
❑ Cl Cl
# Has permittee been free of public complaints in last 12 months?
■
❑ ❑ ❑
Has application occurred during Seasonal Restriction window?
❑
❑ 0 ❑
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) ❑ ❑ ❑ ❑
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 08/07/2012 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
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)
❑ ❑ ■ ❑
e. Time/Temp on:
Cl ❑ ■ ❑
Digester (MCRT)
❑
Compost
❑
Class A lime stabilization
❑
f. Volatile Solids Calculations
❑ ❑ ■ ❑
g. Bench -top Aerobic/Anaerobic digestion results
❑ ❑ ■ ❑
Comment:
T-4.... 6
VPs Nn No NF
Check all that apply
Aerobic Digestion ■
Anaerobic Digestion ❑
Alkaline Pasteurization (Class A) ❑
Alkaline Stabilization (Class B) Cl
Compost ❑
Drying Beds Q
Other ❑
Comment:
Page: 4

Permit: WQ0019960
SOC:
County: McDowell
Region: Asheville
Compliance Inspection Report
Effective: 08/20/07 Expiration: 07/31/16 Owner: City of Marion
Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
PO Drawer 700
Marion NC 28752
Contact Person: J Robert Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
System Classifications: LAB
Primary ORC: Dennis Key Certification: 15704 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name Larry Dean Carver Phone: [phone]
On -site representative Larry Dean Carver Phone: [phone]
Related Permits:
Inspection Date: 08/07/2012 Entry Time: 09:30 AM Exit Time: 10:30 AM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: .Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions N Record Keeping Treatment Pathogen and Vector
Attraction
J
(See attachment summary) o c ;2
c,M -
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 08/07/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 08/07/2012 Inspection Type: Compliance Evaluation
Reason for Visit:
Routine
Record Keeping
Yes No
NA NE
Is GW monitoring being conducted, if required?
❑ ❑
❑
Are GW samples from all MWs sampled for all required parameters?
Cl ❑
,,(
04/❑
Are there any GW quality violations?
❑ El❑'C
❑
Is GW-59A certification form completed for facility?
El ❑
+� ❑
Is a copy of current permit on -site?
6 ❑
❑ ❑
Are current metals and nutrient analysis available? ��;'1 r�
0 ❑
❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
❑
❑ ❑
a. TCLP analysis?�� �' U`'`' `'/
❑ ❑
❑
b. SSFA (Standard Soil Fertility Analysis)? V v ��. �C. ����� S
++
' 2.C1 ❑ ❑
❑
Are PAN balances being maintained?
19 ❑
❑ ❑
Are PAN balances within permit limits?e.s•- aott
0- ❑
❑
Has land application equipment been calibrated?
❑ ❑
❑ it
Are there pH records for alkaline stabilization?
11 ❑
❑
Are there pH records for the land application site?
❑
❑ 0
Are nutrient/crop removal practices in place?
❑ ❑
❑ 0
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?
W ❑
❑ ❑
Has application occurred during Seasonal Restriction window? j4O re �-Ac Um iq
❑ ❑
OR ❑
Comment:
Pathogen and Vector Attraction
Yes
NA NE
A
�No
Xr`'_ ❑
14 ❑
a. Fecal coliform SM 9221 E (Class orb
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
1W -a- '3'y
Ft"fn- ` `
❑
❑
Fecal coliform SM 9222 D (Class B only)
%I 13 .a U(Z �. Ll '3'Z t y N 4 3S-
u�
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)
❑ ❑
I ❑
c. pH records for alkaline stabilization (Class B)
❑ ❑
q ❑
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 08/07/2012 Inspection Type: Compliance Evaluation
Reason for Visit:
Routine
Temperature corrected
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
n
e. Time/Temp on:
n
000
Digester (MCRT)
n
Compost
n
Class A lime stabilization
n
f. Volatile Solids Calculations
n
n
G� n
g. Bench -top Aerobic/Anaerobic digestion results
n
n
Q n
Comment: 50:-JL (0 5 C�tc _i7j n04 pc.:
i iL
/
T___a.Y__a
YPc
Nn
NA NE
Check all that apply
Aerobic Digestion U z`^' `` jLS _ J
Anaerobic Digestion
Alkaline Pasteurization (Class A) n
Alkaline Stabilization (Class B) n
Compost n
Drying Beds n
Other n
Comment:
Page: 4

YAA
y A
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
December 7, 2011
CERTIFIED MAIL 70091680 0000 7515 2717
RETURN RECEIPT REQUESTED
Robert Boyette, City Manager
City of Marion
Post Office Drawer 700
Marion, NC 28752
Subject: Notice of Violation
NOV-2011-PC-0622
Permit No. WQ0019960
McDowellCounty
Dear Mr. Boyette,
On September 30, 2011, staff of the NC Division of Water Quality (DWQ), Aquifer Protection Section
(APS), inspected the subject wastewater treatment and disposal system. The inspection included a review
of the 2010 Annual Report (AR). We wish to thank Mr. David Key, ORC, who was present and assisted
during the inspection.
The following item specifies the permit condition that was in violation during the time of the inspection.
(Also please refer to the attached inspection report):
MONITORING AND REPORTING REQUIREMENTS
Condition IV.5., requires that a representative soils analysis (i.e., Standard Soil Fertility Analysis)
shall be conducted on each land application site on which a residuals land application event in the
respective calendar year has occurred or is to occur, and the results shall be maintained on file by
the Permittee for a minimum of five (5) years. The Standard Soil Fertility Analysis shall include,
but is not necessarily limited to, the following parameters:
Acidity
Exchangeable Sodium Percentage (by calculation)
Calcium
Magnesium
Phosphorous
Cation Exchange Capacity
Manganese
Potassium
Copper
Percent Humic Matter
Sodium
Base Saturation (by calculation)
pH
Zinc
AQUIFER PROTECTION SECTION —Asheville Regional Office (ARO)
2090 U.S. 70 Highway, Swannanoa, NC 28778-8211
Phone: [phone] FAX: [phone]
One
Customer Service:1-877-623-6748
NorthCarolina
Internet: www.ncwaterouality.org
to ll
An Equal Opportunity \ Affirmative Action Employer
/� (�C!
atffr
• ' ff

Mr. Boyette
Permit No. WQ0019960
December 7, 2011
Page 2of 2
As of the DWQ review on September 30, 2011, the soils analysis had been conducted; however
the following parameters were not analyzed: Copper, Zinc and Manganese.
Southern Soil Builders has already provided a written explanation and corrective action to the
above subject violation so no additional response is necessary. However, should you have
additional information or comments which you wish to present concerning the violation, please
submit them to the attention of Beverly Price.
Failure to comply with conditions in a permit may result in a recommendation of enforcement action, to
the Director of the Division of Water Quality who may issue a civil penalty assessment of not more that
twenty-five thousand ($25,000) dollars against any "person" who violates or fails to act in accordance
with the terms, conditions, or requirements of a permit under authority of G.S. 143-215.6A. Please note
that each day a violation continues may be considered a separate violation, subject to additional civil
penalties.
If you have any questions concerning this Notice, please contact Beverly Price at 828-296-4685 or me at
828-296-4500 Ext.4680.
Sin�cereI
G. Landon Davidson, L.G.
Aquifer Protection Section Supervisor
attachment:
cc: McDowell County Environmental Health Department
WO APS_--N,1es
Aquifer Protection Section Central Files

Compliance Inspection Report
Permit: WQ0019960 Effective: 08/20/07 Expiration: 07/31/16 Owner: City of Marion
SOC: Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
County: McDowell PO Drawer 700
Region: Asheville
Marion NC 28752
Contact Person: J Robert Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
System Classifications: LA,
Primary ORC: Dennis Key Certification: 15704 Phone: [phone]
Secondary ORC(s):
David W Key Certification: 23629 Phone: [phone]
On -Site Representative(s):
24 hour contact name David W Key Phone: [phone]
On -site representative David W Key Phone: [phone]
Related Permits:
Inspection Date: 09/30/2011 Entry Time: 10:30 AM Exit Time: 11:30 AM
Primary Inspector:. Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment Land Application Site
■ Pathogen and Vector . Transport
Attraction
(See attachment summary)
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/30/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The inspection included a review of the 2010 Annual Report(AR)as well as a site inspection.
Land application was ocurring on Field K-1; this field is fenced. Buffers were flagged.
Field K-2 now has a small vinyard and a water supply well. The permit should be modified to show a reduction in acreage.
AR Issues:
1) The PathogenNector Attraction Reduction (VAR) Certification Form was not complete. The form should be completed
and re -submitted.
2)The 2010 Soils Analysis was missing 3 parameters: copper, Zinc and Manganese. Please re -submit the report including
the missing parameters.
3) The SOUR Test is used to verify VAR. The maximum hold time for this analysis is 2 hours including any aeration time.
It appears that the samples analyzed were kept aerated until analysis began but that the maximum hold time of two hours
was exceeded.
Response to Additional Information Request for missing soil parameters indicates that Zinc, Copper & Managnese were
not included in the 2010 Analysis.
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/30/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type Yes No NA NE
Distribution and Marketing ❑
Land Application
Record Keeping
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?
■
Comment: -
`Pathogen and Vector Attraction
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) ❑ ❑ ■ ❑
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/30/2011 Inspection Type: Compliance Evaluation
Reason for Visit:
Routine
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)
❑ ❑
■
Cl
e. Time/Temp on:
❑ ❑
■
❑
Digester (MCRT)
❑
Compost
❑
Class A lime stabilization
❑
f. Volatile Solids Calculations
❑ ❑
■
❑
g. Bench -top Aerobic/Anaerobic digestion results
❑ ❑
■
❑
Comment:
T.....b.......b
V.. Mn
MA
MF
Check all that apply
Aerobic Digestion
■
Anaerobic Digestion
❑
Alkaline Pasteurization (Class A)
❑
Alkaline Stabilization (Class B)
❑
Compost
❑
Drying Beds
❑
Other
❑
Comment:
T­-.b V.. Mn AIA AIC
Is a copy of the permit in the transport vehicle? ■ -❑ - ❑ ❑-
Is a copy Of the spill control plan in the vehicle? ■ ❑—❑ Is the the spill control plan satisfactory? ■ ❑ ❑ ❑
Does transport vehicle appear to be maintained? ■ ❑ ❑ ❑
Comment:
Land Application Site Yes No NA NE
- -
Is acopy of -the permit on --site during application -events?- - ■ - - - ❑ ❑- -- -
Page: 4

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/30/2011 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Is the application site in overall good condition?
■ ❑ ❑ ❑
Is the site free of runoff/ponding?
■ ❑ ❑ ❑
If present, is the application equipment in good operating condition?
■ ❑ ❑ ❑
Are buffers being maintained?
■ ❑ ❑, ❑
Are limiting slopes buffered?
10% for surface application
■ ❑ ❑ ❑
18% for subsurface application
❑ ❑ ■ ❑
Are there access restrictions and/or signs?
■ ❑ ❑ ❑
Is the application site free of odors or vectors?
■ ❑ ❑ ❑
Have performance requirements for application method been met?
For injection?
❑ ❑ ■ ❑
For incorporation?
❑
❑ ■ ❑
Does permit require monitoring wells?
❑
■ ❑ ❑
Have required MWs been installed?
❑
❑ ■ ❑
Are MWs properly located w/ respect to RB and CB?
❑
❑ ■ ❑
Are MWs properly constructed (including screened interval)?
❑
❑ ■ ❑
Is the surrounding area served by public water?
❑
■ ❑ ❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
■
❑ ❑ ❑
Are soil types consistent w/ Soil Scientist report/evaluation?
❑
❑ ❑ ■
Is the water table greater than 173' bls.
❑
❑ ❑ ■
Is application occurring at the time of the inspection?
■
❑ ❑ ❑
_C- omments _�-Monitoring_wells-are-not_reguired---- - ---- -- - -- ------ ---------------
---.------------_.—__—._.
--
Page: 5

r�l�
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
November 17, 2011
Robert Boyette, City Manager
City of Marion
Post Office Drawer 700
Marion, NC 28752
SUBJECT: REQUEST FOR ADDITIONAL INFORMATION
REGARDING
Compliance Evaluation Inspection
City of Marion
Land Application of Residual Solids
Permit No: W00019960
McDowell County
Dear Mr.Boyette:
In order to close the inspection records, I need additional information regarding the inspection that I
conducted on September 30, 2011.
The inspection included a review of the 2010 Annual Report (AR). - The following parameters were missing
from the 2010 AR Soils Analysis: Copper, Zinc and Manganese. In addition, the Pathogen and Vector Attraction
Reduction (VAR) Certification Form was not properly filled out. Please complete and resubmit the Certification Form.
Please provide the above information to the Asheville Regional Office by December 1, 2011. Another issue
noted during the 2010 AR review was regarding the Specific Oxygen Uptake Rate (SOUR) Test. The SOUR Test is
used to verify VAR. The maximum holding time for this analysis is 2 hours, including aeration time. According to the
bench sheets submitted, the hold time was exceeded. Please ensure that the proper hold time is met for future
analyses.
Lastly, it appears that a portion of land application Field K-1 now has a small vineyard and a water supply
well. The permit should be modified to show a reduction in acreage for Field K-1.
If -you or your staff has any questions, please call me at 828/296-4685. The assistance of LarryCarver and
David Key was greatly appreciated during the inspection.
Sincerely,
4
Beverly Price
Environmental Specialist
Enclosures
cc: Larry Carver, Wastewater Superintendent w/enclosures
Dennis Key, ORC SSB
APS Central Files
WARS -A -A- sheutlte-.@Ies01
AQUIFER PROTECTION SECTION — Asheville Regional Office (ARO)
2090 U.S. 70 Highway, Swannanoa, NC 28778-8211
Phone: [phone] FAX: [phone] One
Customer Service,1-877-623-6748 NorthCarolina
Internet: www.n;aterauality.org t l
An Equal Opportunity 1 Affirmative Action Employer Aj" m"r a" iff

Permit: WQ0019960
SOC:
County: McDowell
Region: Asheville
Compliance Inspection Report
Effective: 08/20/07 Expiration: 07/31/16 Owner: City of Marion
Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
PO Drawer 700
Marion NC 28752
Contact Person: J Robert Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
System Classifications: LA,
Primary ORC: Dennis Key
Certification: 15704 Phone: [phone]
Secondary ORC(s):
David W Key
Certification: 23629 Phone: [phone]
On -Site Representative(s):
24 hour contact name David W Key
Phone: [phone]
On -site representative David W Key
Phone: [phone]
Related Permits:
Inspection Date: 09/30/2011 Entry Time: 10:30 AM Exit Time: 11:30 AM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: 0 Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment Land Application Site
■ Pathogen and Vector Transport
Attraction
(See attachment summary)
Page: 1

Permit: W00019960 Owner - Facility: City of Marion
Inspection Date: 09/30/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
,The inspection included a review of the 2010 Annual Report(AR)as well as a site inspection.
Land application was ocurring on Field K-1; this field is fenced. Buffers were flagged.
Field K-2 now has a small vinyard and a water supply well. The permit should be modified to show a reduction in acreage.
AR Issues:
1) The PathogenNector Attraction Reduction (VAR) Certification Form was not complete. The form should be completed
and re -submitted.
2)The 2010 Soils Analysis was missing 3 parameters: copper, Zinc and Manganese. Please re -submit the report includinc
the missing parameters.
3) The SOUR Test is used to verify VAR. The maximum hold time for this analysis is 2 hours including any aeration time.
It appears that the samples analyzed were kept aerated until analysis began but that the maximum hold time of two hours
was exceeded.
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/30/2011 Inspection Type: Compliance Evaluation Reason for Visit: 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?
■
❑
Cl ❑
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?
■
❑
❑ 0
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?
❑
❑
■ 0
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) ❑ ❑ ■
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/30/2011 Inspection Type: Compliance Evaluation
Reason for Visit:
Routine
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)
❑
❑
■
❑
e. Time/Temp on:
❑
❑
■
❑
Digester (MCRT)
❑
Compost
❑
Class A lime stabilization
❑
f. Volatile Solids Calculations
❑
❑
■
❑
g. Bench -top Aerobic/Anaerobic digestion results
n
n
■
❑
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:
Transport
Yes No
NA
NE
Is a copy of the permit in the transport vehicle?
■
❑
❑
❑
Is a copy of the spill control plan in the vehicle?
■
❑
❑
❑
Is the spill control plan satisfactory?
■
❑
❑
❑
Does transport vehicle appear to be maintained?
■
❑
n
n
Comment:
Land Application Site
Yes No
NA
NE
Is a copy of the permit on -site during application events?
■
❑
❑
❑
Page: 4

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/30/2011 Inspection Type: Compliance Evaluation
Reason for Visit:
Routine
Is the application site in overall good condition?
■ ❑
❑
❑
Is the site free of runoff/ponding?
■ ❑
❑
0
If present, is the application equipment in good operating condition?
■ ❑
❑
❑
Are buffers being maintained?
■ ❑
❑
❑
Are limiting slopes buffered?
10% for surface application
■
❑
❑ ❑
18% for subsurface application
❑
❑
■ ❑
Are there access restrictions and/or signs?
■
❑
❑ ❑
Is the application site free of odors or vectors?
■
❑
❑ ❑
Have performance requirements for application method been met?
For injection?
❑ ❑
■ ❑
For incorporation?
❑ ❑
■ ❑
Does permit require monitoring wells?
❑ ■
❑ ❑
Have required MWs been installed?
❑ ❑
■ ❑
Are MWs properly located w/ respect to RB and CB?
❑ ❑
■13
Are MWs properly constructed (including screened interval)?
❑ ❑
■ 0-
Is the surrounding area served by public water?
❑ ■
❑ ❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
■ ❑
❑ ❑
Are soil types consistent w/ Soil Scientist report/evaluation?
❑ ❑
❑ ■
Is the water table greater than 173' bls.
❑ ❑
❑
Is application occurring at the time of the inspection?
■ ❑
❑ ❑
Comment: Monitoring wells are not required.
Page: 5

Permit: WQ0019960
SOC:
County: McDowell
Region: Asheville
Compliance Inspection Report
Effective: 08/20/07 Expiration: 07/31/16 Owner: City of Marion
Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
PO Drawer 700
Marion NC 28752
Contact Person: J Robert Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
System Classifications: LAB
Primary ORC: v��n'S K�'� Certification: Phone:
Secondary ORC(sx D0 ; -01
On -Site Representative(s): 1>*,vi cV �-&5
Related Permits:
Inspection Date: 09/30/2011 Entry Time: 10:30 AM Exit Time: 11:30 AM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment Sampling
Land Application Site ■ Pathogen and Vector ■ Transport
Attraction
(See attachment summary)
Appl j; n1n o r4
,Qj ��� now �>qT
S -t-0 bj_ ,n045���d,
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/30/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/30/2011 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Record Keeping
Yes No NA NE
Is GW monitoring being conducted, if required?
❑ ❑ 0 ❑
Are GW samples from all MWs sampled for all required parameters?
❑ ❑ 0 0
Are there any GW quality violations?
❑ ❑ WM 6
Is GW-59A certification form completed for facility?
❑ ❑ q( ❑
Is a copy of current permit on -site?
10 ❑ ❑ ❑
Are current metals and nutrient analysis available? ��� `� �. (0 A_Q—
Aj ❑ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
❑ ❑ ❑
a. TCLP analysis?
0
b. SSFA (Standard Soil Fertility Analysis)?
❑ ❑ ❑
Are PAN balances being maintained?
�0 . ❑ ❑ ❑
Are PAN balances within permit limits?
A ❑ ❑ ❑
Has land application equipment been calibrated?
❑ ❑ ❑ 0
Are there pH records for alkaline stabilization?
❑ 0 ❑
Are there pH records for the land application site?
o�❑,
❑ ❑ ❑
Are nutrient/crop removal practices in place? &rX2eA
, ❑ ❑ ❑
Do lab sheets support data reported on Residual Analysis Summary?
❑ ❑ ❑
Are hauling records available?
p ❑ ❑ ❑
Are hauling records maintained and up-to-date?
9 ❑ ❑ ❑
# Has permittee been free of public complaints in last 12 months?
❑ ❑ 0
Has application occurred during Seasonal Restriction window?
❑ ❑ rM W ❑
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)
040
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
❑
❑
❑ W ❑
b. pH records for alkaline stabilization (Class A) .
c. pH records for alkaline stabilization (Class B)
❑
❑ 1g,0
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/30/2011 Inspection Type: Compliance Evaluation
Reason for Visit: 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::
V..
Mn NA IdC
Check all that apply
Aerobic Digestion
Anaerobic Digestion
❑
Alkaline Pasteurization (Class A)
❑
Alkaline Stabilization (Class B)
❑
Compost
❑
Drying Beds
❑
Other
❑
Comment:
Sampling
Yes No NA NE
Describe sampling:
Is sampling adequate?
❑ ❑ ❑
❑
Is sampling representative?
❑ ❑ ❑
❑
Comment::
Transport _
Yes No NA
NE
Is a copy of the permit in the transport vehicle?
0 ❑ ❑
❑
Is a copy of the spill control plan in the vehicle?
p ❑ ❑
❑
Is the spill control plan satisfactory?
❑ ❑
❑
Does transport vehicle appear to be maintained?
❑ ❑
❑
Comment:
Page: 4

Permit: WO0019960 Owner - Facility: City of Marion
Inspection Date: 09/30/2011 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Land Application Site
Yes No NA NE
Is a copy of the permit on -site during application events?
❑ ❑ ❑
Is the application site in overall good condition?
� ❑ ❑ ❑
Is the site free of runoff/ponding?
❑ ❑ 0
,d
❑ ❑ 0
If present, is the application equipment in good operating condition?
Are buffers being maintained?
❑ ❑ ❑
Are limiting slopes buffered?
❑ ❑ ❑
10% for surface application
18% for subsurface application
❑ ❑ V ❑
J
Are there access restrictions and/or signs? fe-ced — /1 5�5
❑ ❑ Q
❑ ❑ ❑
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
❑ ❑ ro
❑
For incorporation?
❑ ❑
❑
Does permit require monitoring wells?
❑ �( ❑
0
Have required MWs been installed?
❑ ❑ C1
0
Are MWs properly located w/ respect to RB and CB?
❑ ❑
❑
Are MWs properly constructed (including screened interval)?
❑ ❑
❑
Is the surrounding area served by public water?
❑ 0 ❑
❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
1,❑ ❑
❑
Are soil types consistent w/ Soil Scientist report/evaluation?
❑ ❑ ❑
0
Is the water table greater than 173' bls.
❑ ❑ ❑% A
Is application occurring at the time of the inspection?
❑ ❑
❑
Comment:
Page: 5

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
September 30, 2010
J. Robert Boyette, City Manager
City of Marion
Post Office Drawer 700
Marion, NC 28752
SUBJECT: September 23, 2010
Compliance Evaluation Inspection
City of Marion Residuals Land Application
Program
Land Application of Residual Solids (503)
Permit No: WQ0019960
McDowell County
Dear Mr.Boyette:
Enclosed please find a copy of the Compliance Evaluation Inspection form from the
inspection conducted on September 23, 2010. The facility was found to be in Compliance with
permit WQ0019960.
Please refer to the enclosed inspection report for additional observations and comments.
If you or your staff has any questions, please call me at [phone].
Sincerely,
Beverly ice
Environmental Specialist
Enclosure
cc: Dennis Key, ORC
APS Central Files
��,D�A�I°Pe�i�`es�•••
AQUIFER PROTECTION SECTION —Asheville Regional Office (ARO)
2090 U.S. 70 Highway, Swannanoa, NC 28778-8211
Phone: [phone] FAX: [phone]
Customer Service:1-877-623-6748
Internet: www=waterouality.org
An Equal Opportunity 1 Affirmative Action Employer
One
NorthCarolina
NR'tllt'Gdy

Compliance Inspection Report
Permit: WO0019960 Effective: 08/20/07 Expiration: 07/31/15 Owner: City of Marion
SOC: Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
County: McDowell PO Drawer 700
Region: Asheville
Marion NC 28752
Contact Person: J Robert Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Exit 86. Turn left onto Hwy. 226 south. WVVfP is approximately 1/2 mile on the right.
System Classifications: LA,
Primary ORC: Dennis Key Certification: 15704 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name Dennis Key Phone: [phone]
On -site representative Dennis Key Phone: [phone]
Related Permits:
Inspection Date: 09/23/2010 Entry Time: 09:30 AM Exit Time: 10:30 AM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Follow-up Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ■ Compliant Q Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment Sampling
Land Application Site ■ Pathogen and Vector Transport
Attraction
(See attachment summary)
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/23/2010 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Inspection Summary:
The inspection was a follow-up to 2009 Annual Report review. Land application was occurring on Mario Deluca site. The
land application records and field conditions appeared to be compliant with permit conditions.
Page: 2

i
Permit: WO0019960 Owner - Facility: City of Marion
Inspection Date: 09/23/2010 Inspection Type: Compliance Evaluation
Type
Distribution and Marketing
Land Application
Record Keeping
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?
Comment:
Pathogen and Vector Attraction
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)
Reason for Visit: Follow-up
Yes No NA NE
■
Yes No NA NE
■nnn
n
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/23/2010 Inspection Type: Compliance Evaluation
Reason for Visit: Follow-up
Geometric
mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
n
b.
pH records for alkaline stabilization (Class A)
n n
■ n
c.
pH records for alkaline stabilization (Class B)
n n
■ n
Temperature corrected
n
d.
Salmonella (Class A, all test must be < 3MPN/4 gram day)
n n
■ n
e.
Time/Temp on:
n n
■
Digester (MCRT)
n
Compost
n
Class A lime stabilization
n
f.
Volatile Solids Calculations
n n
■ n
g.
Bench -top Aerobic/Anaerobic digestion results
In In
■ n
Comment:
Treatment Yes No NA NE
Check all that apply
Aerobic Digestion ■
Anaerobic Digestion n
Alkaline Pasteurization (Class A) n
Alkaline Stabilization (Class B) n
Compost n
Drying Beds n
Other n
Comment:
Sampling Yes No NA NE
Describe sampling:
Fecals collected over a 2-week period from different points in the digester. SOUR samples also collected
over 2-week period. Metals colllected from digester - composite sampler.
Is sampling adequate? ■ n n In
Is sampling representative? ■ n n n
Comment:
Transport Yes No. NA NE
Is a copy of the permit in the transport vehicle? ■ n n n
Page: 4

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/23/2010 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Is a copy of the spill control plan in the vehicle? ■ ❑ ❑ ❑
Is the spill control plan satisfactory? ■ ❑ ❑ ❑
Does transport vehicle appear to be maintained? ■ ❑ Cl ❑
Comment:
Land Application Site
Is a copy of the permit on -site during application events?
Is the application site in overall good condition?
Is the site free of runoff/ponding?
If present, is the application equipment in good operating condition?
I
Are buffers being maintained?
Are limiting slopes buffered?
10% for surface application
18% for s.jjbsurface application
Are there access restrictions and/or signs?
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
Is the water table greater than 173' bls.
Is application occurring at the time of the inspection?
Comment: MWs not required.
Public water not available.
❑❑■❑
❑❑■❑
❑ ■ ❑ ❑
❑ ❑ ■ ❑
❑ ❑ ■ ❑
❑ ❑ ■ ❑
❑ ■ ❑ ❑
■ ❑ ❑ ❑
❑ ❑ ❑ ■
❑ ❑ ❑ ■
■❑❑❑
Page: 5

Compliance Inspection. Report
Permit: WO0019960 • Effective: 08/20/07 Expiration: 07/31/15 Owner: City of Marion
SOC: Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
County: McDowell PO Drawer 700
Region: Asheville
Marion NC 28752
Contact Person: J Robert Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
System Classifications: LA,
Primary ORC: Dennis Key Certification: 15704 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name Dennis Key Phone: [phone]
On -site representative Dennis Key Phone: [phone]
Related Permits:
Inspection Date: 09/23/2010 Entry Time: 09:30 AM Exit Time: 10:30 AM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Follow-up Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant Cl Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment Sampling
Land Application Site ■ Pathogen and Vector ■ Transport(� Attraction
(See attachment summary)
pan- �- F e 14
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/23/2010 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Inspection Summary:
Page: 2

Permit: WO0019960 Owner - Facility: City of Marion
Inspection Date: 09/23/2010 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Record Keeping Yes No NA NE
Is GW monitoring being conducted, if required? ❑ In X ❑
Are GW samples from all MWs sampled for all required parameters?
❑
❑
El
Are there any GW quality violations?
❑
❑
�}
+i,
❑
Is GW-59A certification form completed for facility?
❑
❑
1P
❑
Is a copy of current permit on -site?
I'd
❑
❑
❑
Are current metals and nutrient analysis available?
W
n
❑
n
Are nutrient and metal loading calculating most limiting parameters?
n
❑
❑
a. TCLP analysis? ®ntv] f�u're� ®`�cc���
❑
n
❑
Wj
b. SSFA (Standard Soil Fertility Analysis)? j ro toot
f�1
n
n
n
Are PAN balances being maintained?
❑
❑
❑
Are PAN balances within permit limits?1
❑
❑
❑
Has land application equipment been calibrated?
❑
❑
❑
Are there pH records for alkaline stabilization?
❑
❑
R
❑
Are there pH records for the land application site? IV( S6%�s 4rA"�5'f
❑
❑
❑
n
Are nutrient/crop removal practices in place? (&m-L4_k
IV
n
n
n
Do lab sheets support data reported on Residual Analysis Summary? 'aq
U
❑
❑
n
Are hauling records available?
W
❑
❑
n
Are hauling records maintained and up-to-date?
m
❑
❑
❑
# Has permittee been free of public complaints in last 12 months?
IN
❑
❑
❑
Has application occurred during Seasonal Restriction window?
❑
❑
P
❑
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❑i
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
+,q�
Fecal coliform SM 9222 D (Class B only)
❑
❑
r,�
+4
❑
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)
n
n
0
n
c. pH records for alkaline stabilization (Class B)
❑
n
W
n
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/23/2010 Inspection Type: Compliance Evaluation
Reason for Visit: Follow-up
Temperature corrected
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
n
n n
e. Time/Temp on:
❑
n n
Digester (MCRT)
n
Compost
n
Class A lime stabilization
n
f. Volatile Solids Calculations
p
n q n
g. Bench -top Aerobic/Anaerobic digestion results
n
n ." n
Comment:
Treatment Yes No NA NE
Check all that apply
Aerobic Digestion
x
Anaerobic Digestion
n
Alkaline Pasteurization (Class A)
n
Alkaline Stabilization (Class B)
n
Compost
n
Drying Beds
n
Other
n
Comment:
Sampling, �n Yes No NA NE
Describe sampling:
yLk-
Is sampling adequate? cJ ��z� QJ v� a-c,v(C� 0d n n n
co C�
Is sampling representative? mAoJS4 ou`So (1 �µ dugs ` t► g� k1 n n n
6 Comment: a' ` / e C& sl �
p$ �[�G �l
Transport Sauk—ff I ¢� Yes No NA NE
Is a copy of the permit in the transport vehicle? m n n n
Is a copy of the spill control plan in the vehicle? n n n
Is the spill control plan satisfactory? f n ❑ n
Does transport vehicle appear to be maintained?1 n ❑ ❑
Comment:
Page: 4

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/23/2010 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Land Application Site
Yes No
NA
NE
��� / G'��r
10 ❑
❑
Is a copy of the permit on -site during application events? VVX
Is the application site in overall good condition? G"P�i❑❑❑
Is the site free of runoff/ponding?
y1i ❑
❑
❑
If present, is the application equipment in good operating condition?
❑
❑
❑
Are buffers being maintained?
❑
0
❑
Are limiting slopes buffered?
1.0% for surface application
18% for subsurface application
❑ ❑ P ❑
Are there access restrictions and/or signs?
A ❑ ❑ ❑
Is the application site free of odors or vectors?
19 ❑ ❑ ❑
Have performance requirements for application method been met?
For injection?
❑ ❑ k ❑
For incorporation?
❑ ❑ lo❑
Does permit require monitoring wells?
❑ t ❑ ❑
❑
Have required MWs been installed?
2P
Are MWs properly located w/ respect to RB and CB?
❑ ❑ 1� ❑
Are MWs properly constructed (including screened interval)?
❑ ❑ ❑
Is the surrounding area served by public water?
❑ Ell ❑ ❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
❑ ❑ ❑
Are soil types consistent w/ Soil Scientist report/evaluation?
❑ ❑ ❑
Is the water table greater than 173' bls.
❑ ❑ ❑
Is application occurring at the time of the inspection?
❑ ❑ ❑
Comment:
Page: 5

I I �" "r
A4
j� �E Co
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
September 8, 2010
J. Robert Boyette, City Manager
City of Marion
Post Office Drawer 700
Marion, NC 28752
SUBJECT: September 8, 2010
Compliance Evaluation Inspection
City of Marion Residuals Land Application
Program
Land Application of Residual Solids (503)
Permit No: WQ0019960
McDowell County
Dear Mr. Boyette:
Enclosed please find a copy of the Compliance Evaluation Inspection form from the
inspection conducted on September 8, 2010. The facility was found to be in Compliance with
permit WQ0019960.
The inspection consisted of a review of the 2009 Annual Report (AR). The following
parameters were not included in the TCLP Analysis: 2,4-D; Silvex; Ignitability; Corrosivity;
Reactivity. If the parameters were not analyzed, you have until the next permit renewal to
perform the analysis. If these parameters were inadvertently left out of the AR please submit the
missing data within 10 days to the following address:
NCDENR
Division of Water Quality
Aquifer Protection Section
Land Application Unit
1636 Mail Service Center
Raleigh, NC 27699-1636
Attn: Ed Hardee
AQUIFER PROTECTION SECTION —Asheville Regional Office (ARO)
2090 U.S. 70 Highway, Swannanoa, NC 28778-8211
Phone: [phone] FAX : [phone]
Customer Service:1-877-623-6748
Internet: www.ncwaterquality.orq
An Equal Opportunity l Affirmative Action Employer
One
NorthCarolin.a
Naturally

Mr. Boyette
September 8, 2010
Page 2 .
Please refer to the enclosed inspection report for additional observations and comments.
If you or your staff has any questions, please call me at [phone].
Sincerely, P',:'
///�^// ///
�B✓✓overly ice
Environmental Specialist
Enclosure
cc: Dennis Key, ORC SSB w/enclosure
Larry Carver, ORC City of Marion WWTP w/enclosure
APS Central Files
�WP°i

Compliance Inspection Report
Permit: W00019960 Effective: 08/20/07 Expiration: 07/31/15 Owner: City of Marion
SOC: Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
County: McDowell PO Drawer 700
Region: Asheville
Marion NC 28752
Contact Person: J Robert Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
System Classifications: LA,
Primary ORC: Dennis Key Certification: 15704 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name Dennis Key Phone: [phone]
Related Permits:
Inspection Date: 09/08/2010 Entry Time: 11:30 AM Exit Time: 12:30 PM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions 0 Record Keeping Treatment Pathogen and Vector
Attraction
(See attachment summary)
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 0910812010 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The inspection consisted of a review of the 2009 Annual Report (AR). Land application is scheduled within the next 3
weeks and a field inspection will be conducted at that time.
A.R. Issues:
1)The TCLP Analysis did not include the following parameters: 2,4-D; Silvex; Ignitability; Corrosivity; Reactivity
2)The SOUR test performed on 4/3/09 & 4/20/09 did not meet the hold time of two hours.
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/08/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type Yes No NA NE
Distribution and Marketing Q
Land Application
■
Record Keeping
Yes No
NA
NE
Is GW monitoring being conducted, if required?
❑
n
■
❑
Are GW samples from all MWs sampled for all required parameters?
11
n
■
n
Are there any GW quality violations?
■
Is GW-59A certification form completed for facility?
Q
Q
■
Is a copy of current permit on -site?
❑
❑
Q
U
Are current metals and nutrient analysis available?
■
n
Q
Q
Are nutrient and metal loading calculating most limiting parameters?
■
n
Q
n
a. TCLP analysis?
■
❑
0
n
b. SSFA (Standard Soil Fertility Analysis)?
■
❑
❑
❑
Are PAN balances being maintained?
■
El
n
Are PAN balances within permit limits?
■
❑
❑
n
Has land application equipment been calibrated?
n
O
Q
■
Are there pH records for alkaline stabilization?
❑
❑
■
❑
Are there pH records for the land application site?
■
n
n
Ci
Are nutrient/crop removal practices in place?
0
n
0
■
Do lab sheets support data reported on Residual Analysis Summary?
■
n
n
Are hauling records available?
■
Q
n
❑
Are hauling records maintained and up-to-date?
■
Q
Q
❑
# Has permittee been free of public complaints in last 12 months?
❑
❑
❑
■
Has application occurred during Seasonal Restriction window?
11
n
■
n
Comment:
Pathogen and Vector Attraction Yes No NA NE
a. Fecal coliform SM 9221 E (Class A or B) ■ n O 0
Class A, all test must be <1000 MPN/dry gram n
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) ■ n
0 Cl
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 09/08/2010 Inspection Type: Compliance Evaluation
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)
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench -top Aerobic/Anaerobic digestion results
Comment:
Treatment
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Comment:
Reason for Visit: Routine
■
nn■❑
nn■n
n
nn■n
nn■n
n
n
n
❑❑■n
nn■n
■
n
n
n
n
n
Page: 4

NCDENR
North Carolina Department of Environment and Natura
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
May 15, 2009
J. Robert Boyette, City Manager
City of Marion
Post Office Drawer 700
Marion, NC 28752
Resources
(01 ca Ile Y
SUBJECT: May 5, 2009
Compliance Evaluation Inspection
City of Marion
City of Marion Residuals Land
Application Program
Land Application of Residual Solids (503)
Permit No: WQ0019960
McDowell County
Dear Mr. Boyette:
Dee Freemal
Secretar,
Enclosed please find a copy of the Compliance Evaluation Inspection form from the
inspection that I conducted on May 5, 2009. The facility was found to be in Compliance. with
permit WQ0019960.
The inspection included a review of the 2008 Annual Report (AR). The following data
was missing from the Annual Report:
1) The Sodium Adsorption Ratio (SAR) Calculation. See Permit Condition 11.11.
2) The AR showed Alternative 1 for Vector Attraction Reduction. According to Larry Carver,
Alternative 4 (SOUR Test) is being used to verify VAR. There was no documentation in
the AR to verify VAR. See Permit Condition IVA.
3) Fields F-03 & F-04 showed pH values of 5.3 & 5.6 respectively. The Field Summary
Forms did not indicate the addition of lime to these fields. See Permit Condition 111.11.h.
North Carolina Division of Water Quality — Asheville Regional Office 2090 U.S. Highway 70 Swannanoa, NC 28778
Aquifer Protection Section
Customer Service 1-877-623-6748
Internet: h2o.enr.state.nc.us
NorthCarolina
Natura!!jl
Phone [phone]
FAX [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

Mr. Boyette
May 15, 2009
Page 2
Please submit the above referenced information in triplicate, within 10 days of receipt of
this letter to the attention of Ed Hardee at:
NCDENR
Division of Water Quality
Aquifer Protection Section
Land Application Unit
1636 Mail Service Center
Raleigh, NC 27699-1636
Please refer to the enclosed inspection report for additional observations and comments.
The assistance of Mr. Larry Carver was greatly appreciated during the inspection. If you or your
staff has any questions, please call me at [phone].
Sincerely,
Beverly rice
Environmental Specialist
Enclosure
cc: Dennis Key, ORC SSB w/enclosure
Larry Carver, ORC City of Marion WWTP w/enclosure
APS Central Files
ies

Compliance Inspection Report
Permit: WQ0019960 Effective: 08/20/07 Expiration: 07/31/12 Owner: City of Marion
SOC: Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
County: McDowell PO Drawer 700
Region: Asheville
Marion NC 28752
Contact Person: J Robert Boyette Title: City Manager Phone: [phone]
Directions to Facility:
From ARO: 1-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
System Classifications:
Primary ORC: Dennis Key Certification: 15704
Phone: [phone]
Secondary ORC(s):
David W Key Certification: 23629
Phone: [phone]
On -Site Representative(s):
24 hour contact name Larry Dean Carver
Phone: [phone]
On -site representative Larry Dean Carver
Phone: [phone]
Related Permits:
Inspection Date: 05/05/2009 Entry Time: 10:00 AM Exit Time: 11:30 AM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: W Compliant ❑ Not Compliant
Question Areas:
® Miscellaneous Questions IS Record Keeping ® Treatment ® Sampling
Pathogen and Vector
Attraction
(See attachment summary)
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 05/05/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The inspection was scheduled to include an application event but had to be rescheduled due to rain. The inspection did
include a records review for the current application event in addition to a review of the 2008 Annual Report (AR).
PathogenNAR data for the current application appeared to be accurate and meet permit conditions.
An Additional Information Request will be sent to address missing data in the 2008 AR.
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 05/05/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type Yes No NA NE
Distribution and Marketing ❑
Land Application
Record Keeping
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?
Comment:
Pathogen and Vector Attraction
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)
■
Yes
No
NA
NE
❑
❑
■
❑
❑❑■❑
❑
❑
■
❑
❑❑■❑
■
0
❑
❑
■❑❑❑
■
❑
❑
❑
■
❑
❑
❑
■
❑
❑
❑
■
❑
n
❑
■
❑
❑
❑
❑
❑
❑
■
❑
❑
■
❑
■
❑
❑
❑
■
❑
❑
❑
■
❑
❑
❑
❑❑❑■
❑
❑
❑
■
■❑❑❑
❑
❑
■
❑
Yes
No
NA
NE
■
❑
❑
❑
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 05/05/2009 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
n
b.
pH records for alkaline stabilization (Class A)
In
n
■
n
c.
pH records for alkaline stabilization (Class B)
n
n
■
n
Temperature corrected
n
d.
Salmonella (Class A, all test must be < 3MPN/4 gram day)
n
n
®
n
e.
Time/Temp on:
rinnn
Digester (MCRT)
n
Compost
Q
Class A lime stabilization
In
f.
Volatile Solids Calculations
n
n
■
n
g.
Bench -top Aerobic/Anaerobic digestion results
n
n
■
n
Comment:
Treatment
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Comment:
Sampling
Describe sampling:
Fecal samples are collected over period of 2 wks. fromdifferent locations in the digester. Seven fecals are
collected. TCLP, metals, residuals samples are collected at the same time. Seven to ten grabs are collected
and then composited.
Is sampling adequate?
Is sampling representative?
Comment:
■
n
n
n
n
n
n
Yes No NA NE
■nnn
■nnn
Page: 4

Permit: WQ0019960
SOC:
County: McDowell
Region: Asheville
Compliance Inspection Report
Effective: 08/20/07 Expiration: 07/31/12 Owner: City of Marion
Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
PO Drawer 700
Contact Person: J Robert Boyette
Directions to Facility:
System Classifications:
Primary ORC: Dennis Key
Secondary ORC(s):-
On-Site Representative(s):
Related Permits:
Inspection Date: 05/05/2009
Primary Inspector: Beverly Price
Secondary Inspector(s):
Title: City Manager
Certification: 15704
Marion NC 28752
Phone: [phone]
Entry Time: 10:00 AM Exit Time: 11:30 AM
Phone: [phone]
Phone: [phone]
Reason fof Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment Sampling
Land Application Site ■ Pathogen and Vector ■ Transport
Attraction
(See attachment summary)
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 05/05/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: WO6019960 Owner - Facility: City of Marion
Inspection Date: 05/05/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
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?
Q
❑ ❑
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?
❑
❑
0 ❑
Are there pH records for the land application site?
❑
❑ ❑
Are nutrient/crop removal practices in place? 6Tp-A2ed-(/ '
Iff
❑
❑ ❑
Do lab sheets support data reported on Residual Analysis Summary?
W
❑
❑ ❑
Are hauling records available? V10A 2Vaiu.o (_— L,A- U&N3 pC&A-po,\e-d dui 10
❑
❑
❑
n
Are hauling records maintained and 'up-to-date?�
❑
❑
❑
# Has permittee been free of public complaints in last 12 months?
15
❑
❑ ❑
Has application occurred during Seasonal Restriction window?
❑
❑
10 ❑
Comment:
Pathogen and Vector Attraction
Yes
No
NA NE
a. Fecal coliform SM 9221 E (Class A or B) '��
0
❑
❑ ❑
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) -
❑
0,40
C. pH records for alkaline stabilization (Class B)
❑
❑
svt ❑
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 05/05/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Temperature corrected Q 5 ,
d. Salmonella (Class A, all test must be < 3MPN/4 gram day) ❑ ❑ IiL�
e. Time/Temp on: ❑
o In
Digester (MCRT) fl
Compost 11
Class A lime stabilization 1-1
f. Volatile Solids Calculations ❑ ❑ ry ❑
g. Bench -top Aerobic/Anaerobic digestion results ❑ 0 0 ❑
Comment:roV2 iii42 JSOUP- _YJ
Check all that apply
Aerobic Digestion
Anaerobic Digestion 0
Alkaline Pasteurization (Class A) ❑
Alkaline Stabilization (Class B) ❑
Compost 171
Drying Beds
Other ❑
Comment:
Sampling ff (� Yes No NA NE
//
Describe sampling: SOL ,-p
Is sampling adequate? " j-'LL P ���`a c �n i; L'v`�`� o
/
Is sampling representative?
i
Comment:
Transport Yes No NA, NE
Is a copy of the permit in the transport vehicle? n 0
Is a copy of the spill control plan in the vehicle? fl ❑ ❑ c�J
Is the spill control plan satisfactory? 0 fl ❑ 1\
Does transport vehicle appear to be maintained? ❑
Comment:
Page: 4

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 06/05/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Land Application Site Yes No NA NE
Is a copy of the permit on -site during application events? ❑ Cl ❑ ❑
Is the application site in overall good condition?
❑
❑
❑
❑
Is the site free of runoff/ponding? 1
❑
❑
❑
❑
If present, is the application equipment in good operating condition?
❑
❑
❑
❑
Are buffers being maintained?
❑
❑
❑
❑
Are limiting slopes buffered?
10% for surface application
❑
❑
❑
❑
18% for subsurface application
❑
❑
❑
Q
Are there access restrictions and/or signs?
❑
❑
Cl
❑
Is the application site free of odors or vectors?
❑
❑
❑
❑
Have performance requirements for application method been met?
For injection?
❑
❑
❑
❑
For incorporation?
❑
❑
❑
❑
Does permit require monitoring wells?
❑
❑
❑
❑
Have required MWs been installed?
❑
❑
❑
❑
Are MWs properly located w/ respect to RB and CB?
❑
❑
❑
❑
Are MWs properly constructed (including screened interval)?
❑
❑
❑
❑
Is the surrounding area served by public water?
❑
❑
❑
❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
❑
❑
❑
Cl
Are soil types consistent w/ Soil Scientist report/evaluation?
❑
❑
❑
❑
Is the water table greater than 173' bls.
❑
❑
❑
❑
Is application occurring at the time of the inspection?
❑
❑
❑
❑
Comment:
P 1,'UP0/1 0,10s ire-sc4-e-�16W Q/V4, t�
G4Jker> t2p kecA-}`GOh �eJGi
Page: 5

Compliance Inspection Report
Permit: WQ0019960 Effective: 08/20/07 Expiration: 07/31/12 Owner: City of Marion
SOC: Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
C t M D II PO Drawer 700
oun ye c owe
Region: Asheville
Contact Person: J Robert Boyette
Directions to Facility:
System Classifications:
Primary ORC: Dennis Key
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
Related Permits:
Dennis Key
Title: City Manager
Certification: 15704
Marion NC 28752
Phone:[phone]
Phone:[phone]
Phone: [phone]
Inspection Date: 07/21/2008 1Entry Time: 09:00 AM Exit Time: 10:00 AM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ■ Compliant ❑ Not Compliant
Question Areas:
0 Miscellaneous Questions E Record Keeping
(See attachment summary)
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 07/21/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
There was no site visit for this inspection. The inspection consisted of a review of the 2007 Annual Report. SAR
calculation was missing from the AR; an Add -Information letter was sent 7/21/08. SAR calculation was submitted by SSB
on 8/1/08.
Permit requires annual monitoring for PathNAR. Facility usually does 2 applications/yr. Only one sampling event/yr. is
required per Ed Hardee 7/18108.
SOUR Test (Option #4) or 30-Day Bench -Scale Test (Option #3) should be used for VAR in 2008 not Option #1 (38%
Reduction). See 6129/07 letter to David Goodrich regarding VAR.
Page: 2

Permit: WO0019960 Owner - Facility: City of Marion
Inspection Date: 07/21/2008 Inspection Type: Compliance Evaluation Reason for Visit: 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?
❑
❑
■
❑
Comment:
Page: 3

Michael F. Easley, Governor
O� O�WAT�9pG
MEMORANDUM
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
August 6, 2007
TO: Roger Edwaras,.SurfacaVa.tgXrotectiion Supervisor
WINIM", .avclsQn Aqu�t�on .: , ervi� or
DWQ Asheville Regional Office
FROM: Zi-Qiang Chen, Ph.D., Project Manager ?Q- L
Facilities Evaluation Unit
Construction Grants and Loans Section
SUBJECT: City of Marion
Engineering Report
Proposed Wastewater Collection System and
Treatment Plant Improvements
Project No.: To be assigned
Alan W: Klimek, P.E. Director
Division of Water Quality -
AUG 1 0 2007 ,
�V
B
p
orilcri
One copy of the subject Engineering Report is attached for the DWQ Asheville Regional
Office's technical review and comment. The Regional Office's technical input concerning this
project, based on the Region's knowledge of the city's wastewater facilities, will be greatly
appreciated. Please keep this copy of the report for your files and return your comments to this
office by September 5, 2007, if possible.
Thank you for your continued cooperation and responsiveness. If you have any questions, please
contact me at [phone] at your earliest convenience.
S
ct
ZQC:dr
Attachment o�,��,A ice`'
cc: Daniel Blaisdell, P.E.
Mark Hubbard, P.E.
Don Evans
Jennifer Haynie
PMB/DMU/FEU/SRF
Construction Grants and Loans Section One 1 1633 Mail Service Center Raleigh NC 27699-1633 NdrthCar011na
Phone: [phone] / FAX: [phone] / Internet: www.nccgl.net
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper .Aatumlly

-i

BRANCH RESIDUALS & SOILS' LLC
311 B South Westgate Drive • Greensboro, NC 27407
PHONE [phone] • FAX [phone]
June 29, 2007
N.C. Department of Environment and Natural Resources
Aquifer Protection Section
1636.Mail Service Center
Raleigh, NC 27699-1636
ATTENTION: Mr. Dave Goodrich
REFERENCE: City of Marion Additional Information Request
Permit No. WQ0019960
Land Application Permit
BR&S Job No. 2006-51
Dear Mr. Goodrich:
r,
JUL 0 �)
dAshevine '— ✓�
On behalf of the City of Marion and after conversation with Mr. Larry Carver of the City of Marion,
I have prepared a response to the Addition Information Request dated May 30, 2007 (Attachment I).
The City of Marion is aware that there are times that this facility meets the intent of Alternative 1
(38% volatile solids reduction) for Vector Attraction Reduction (VAR) but does not always meet
the letter of the regulation. In order to satisfy the regulations, the City of Marion is proposing to
have a three tiered approach.
1. Initially, the City of Marion will try to meet VAR by SOUR (Specific Oxygen Uptake
Rate) Tests. The City of Marion has been experimenting with the procedure and results
have been included (Attachment II). The samples are collected prior to thickening at the
point of entering the secondary clarifier. This sampling point was identified to me by Dr.
Jim Smith with USEPA-NRMRL in Cincinnati, Ohio as a possible alternate to a
"conventional" SOUR test. I have had conversations with Mr. Mike Hom of EPA Region
4 and Mr. Jon Risgaard of the NCDENR Aquifier Protection Section/ Land Application
Unit and both indicate that the test meets 40 CFR Part 503 definitions and the definitions
imposed by the North Carolina SOUR Guidelines. The rules for this test are simple as
long as the temperature of the digester remains between 10 ° and 30 ° C, the tested solids
are less than 2%, and the arithmetic mean of the SOUR results are less than 1.5 mg
Oxygen/gram/hour. Since the City of Marion performs an application event annually,
SOUR tests will be performed once or twice per month to document the annual
monitoring period for Vector Attraction Reduction.
2. If the SOUR testis not met, the City of Marion will perform a "fish tank test" to verify the
loss of less than 15% additional volatile solids for 20 additional days at 20° C.

City of Marion Additiona brmation Request WQ0019960 June 29, 2007
NCDENR- Aquifer Protection Section BR&S Project No. 2006-51
3. If VAR is not met by either of the previous two options, the City of Marion will meet VAR
by lime stabilization.
As you are well aware, 40 CFR Part 503 does not specify which way a plant should meet it's VAR
requirement. The City of Marion will continue to run SOUR test and study the fish tank test to
determine if they are comfortable with the test and seek lab certification. Based on the preliminary
values, SOUR tests will continue to be performed twice a month to serve as process monitoring.
CLOSING
If you have any question regarding this information, please give me a call at [phone].
Sincerely,
Robert T. Branch, L.S.S.
Project Manger/Soil Scientist
cc: Ms. Bev Price — NCDENR Asheville Regional Office
Mr. Larry Carver — City of Marion WWTP
Mr. Bob Boyette — City of Marion
Attachments:
I May 30, 2007 NCDENR Additional Request Letter
II City of Marion SOUR Tests
2

Attachment I
May 30, 2007 NCDENR Additional Request Letter

W A TF9Q Michael F. Easley, Governor
\O G William G. Ross Jr., Secretary
Cij r North Carolina Department of Environment and Natural Resources
.� Alan W. Klimek, P.E. Director
Division of Water Quality
May 30, 2007
Mr. J. Robert Boyette, City Manager
City of Marion.
P.O. Drawer 700
Marion, NC 28752
Subject: Application No. WQ0019960
Request for Additional Information
City of Marion Land Application Program
Land Application of Residuals
McDowell County .
Dear Mr. Boyette:
The Non -Discharge Permitting Unit has conducted a preliminary review of the subject application for permit
renewal. Additional information is required before we may continue our review. Please address the following items
no later than June 30, 2007.
On Page 8 of FORM RSCA 10-06 of your application, Alternative 1 (38% Volatile Solids Reduction —
Aerobic/Anaerobic Digestion) is selected as the method to verify Vector Attraction Reduction (VAR).
Annual compliance inspections for 2005 and 2006 have shown that the 38% reduction in volatile solids
can only be met when using samples collected at the head of the aeration basin, and compared to those
collected as the sludge exits the digester. The initial sludge sample should be collected at a point just
prior to entering the digester (not at the head of the aeration basin). It is recommended that a different
option be chosen to verify VAR, unless the 38% reduction can be shown using samples collected at the
proper locations.
Please notify both the Asheville Regional Office and the Central Office (addresses below) of your
selected method to verify sufficient Vector Attraction Reduction (VAR), along with the results of the
selected test that clearly demonstrate that it has been used on the residuals and meets the necessary
standards.
NCDENR-DW Q
Aquifer Protection Section
1636 Mail Service Center
Raleigh, NC 27699-1636
NCDENR-DWQ
Aquifer Protection Section
2090 US Highway 70
Swannanoa, NC 28778
'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 responsibility
of the applicant. In addition, any omissions made in responding to the above items may result in future requests for
additional information.
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636
Internet: http://h2o.CnT.state.nc.us 2728 Capital Boulevard Raleigh, NC 27604
An Equal Opportunity/Affirmative Action Employer— 50% Recyded/10% Post Consumer Paper
tCarolina
urally
Telephone: [phone]
Fax 1: [phone]
Fax 2: [phone]
Customer Service: [phone]

Please reference the subject application number when providing the requested information. Please note that failure to
provide this additional information on or before the above requested date may result in your application being
returned as incomplete.
If you have any questions regarding this request, please do not hesitate to contact me at [phone]. You may
also check the future status of this project online at hits://h2o.enr.state.nc.ustbims/Reports/reportsPermits.btml.
Thank you for your cooperation.
Sincerely,
�,�Aoor#
David Goodrich, P.G.
Non -Discharge Permitting Unit
cc: Beverly Price, Winston-Salem Regional Office, Aquifer Protection Section
Robert T. Branch, Branch Residuals & Soils, LLC
Permit Application File WQ0019960

Attachment II
City of Marion SOUR Tests

Jun ca u r u.J: aup U1 1 7 Ur MHK1UN ties b55 155y p. e
Time
(minutes)
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Specific Oxygen Uptake Rate
SOUR
Facility Name: Corpening Cr
Biosolids Permit Number: WQ 0019960
Date: 6/15/
Digester Temperature:
Sampling Date/Time: 6-11-07 103(
Sampled By: L. Estes
Analysis Date/Time: 6-11-07 104
Analyzed By: R. Carter
Sample Volume. -
Total Solids:
Beginning Temperature. -
End Temperature:
Dissolved Oxygen Level
7.
5.48
5.21
4.93
4.66
4.39
liiliters
Dry Solids
grees Celsius
qrees Celsius
Slope: 0.3
Intercept: 7.4
Correlation Coefficient: 1.0
Oxygen Uptake Rate: 16.58 mg Oxygen/hr
Ambient Specific Oxygen Uptake Rate: 1.91 mg Oxygen/g/hr
Average Temperature: 25 degrees Celsius
Temperature Correction Factor: 0.783526166
Temperature Corrected Specific Oxygen Uptake Rate: 1.49 mg Oxygen/g/hr
Instructions: Enter Data in the Blue Boxes. The Calculation and the Spreadsheet execute automatically.

Jun 28 07 03:30p
CITY OF MRRION
828 659 1959
p.3
Time
(minutes)
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Specific Oxygen Uptake Rate
SOUR
Facility Name: Cor enin Cr(
Biosolids Permit Number: WQ 0019960
Date: 6115/1
Digester Temperature:
Sampling Date/Time: 6-12-07 0915
Sampled By: L. Estes
Analysis Date/Time: 6-12-07 095
Analyzed By: R. Carter
Sample Volume: 1
Total Solids:
Beginning Temperature:
End Temperature:
Dissolved Oxygen Level
7
3
Dry Solids
grees Celsius
prees Celsius
Slope. 0.3
1 ntercept: 7.7
Correlation Coefficient: 1.0
Oxygen Uptake Rate: 16.67 mg Oxygen/hr
Ambient Specific Oxygen Uptake Rate: 1.83 mg Oxygen/g/hr
Average Temperature: 25 degrees Celsius
Temperature Correction Factor: 0.783526166
Temperature Corrected Specific Oxygen Uptake Rate:1 1.44 mg Oxygen/g/hr
Instructions: Enter Data in the Blue Boxes. The Calculation and the Spreadsheet execute automatically.

.tun eu ul uj:j1p L117 ur MNK1LIN bea bbb 1U55 p.'4
Time
(minutes)
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Specific Oxygen Uptake Rate
SOUR
Facility Name
Biosolids Permit Number
Date
Digester Temperature
Sampling Date/Time
Sampled By
Analysis Date/Time
Analyzed By
Sample Volume
Total Solids
Beginning Temperature
End Temperature
Dissolved Oxygen Level
6.611
C.
5.1
Corpening Creek
WQ 0019960
6/15/2007
23
6-13-071030
L. Estes
6-13-07 1056
R. Carter
1000
0.96
25
25
Slope: 0.3
Intercept: 7.0
Correlation Coefficient: 1.0
nilliliters
/o Dry Solids
legrees Celsius
iegrees Celsius
Oxygen Uptake Rate: 17.72 mg Oxygen/hr
Ambient Specific Oxygen Uptake Rate: 1.85 mg Oxygenlg/hr
Average Temperature: 25 degrees Celsius
Temperature Correction Factor: 0.783526166
Temperature Corrected Specific Oxygen Uptake Rate: 1.45 mg Oxygen/g/hr
Instructions: Enter Data in the Blue Boxes. The Calculation and the Spreadsheet execute automatically.

Jun 28 07 03:31p CITY OF MRRION 828 659 1959 p.5
Time
(minutes)
0
1
2
3
4
5
6
7
8
9
10
1.1
12
13
14
15
Specific Oxygen Uptake Rate
SOUR
Facility Name
Biosolids Permit Number
Date
Digester Temperature
Sampling Date/Time
Sampled By
Analysis Date/Time
Analyzed By
Sample Volume
Total Solids
Beginning Temperature
End Temperature
Dissolved Oxygen Level
6.511
4
Corpening Creek
WQ 0019960
6/15/2007
22
6-14-071030
L. Estes
6-14-07 1330
R. Carter
1000
0.96
25
25
Slope: 0.2
Intercept: 7.5
Correlation Coefficient: 1.0
nilliliters
Yo Dry Solids
iegrees Celsius
iegrees Celsius
Oxygen Uptake Rate: 14.66 mg Oxygen/hr
Ambient Specific Oxygen Uptake Rate: 1.53 mg Oxygen/g/hr
Average Temperature: 25 degrees Celsius
Temperature Correction Factor: 0.783526166
Temperature Corrected Specific Oxygen Uptake Rate: 1.20 mg Oxygen/g/hr
Instructions: Enter Data in the Blue Boxes. The Calculation and the Spreadsheet execute automatically.

jun eu u-t uj:31p C11Y OF MHRIUN 828 659 1959 p.6
Time
(minutes)
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Specific Oxygen Uptake Rate
SOUR
Facility Name: Co
Biosolids Permit Number. W(
Date:
Digester Temperature:
Sampling Date/Time: 6-1
Sampled By: L. t
Analysis Date/Time: 6-1
Analyzed By: R. I
Sample Volume:
Total Solids:
Beginning Temperature:
End Temperature:
Dissolved Oxygen Level
7.091
6.761
A
4.741
A
1000 milliliters
0.89 % Dry Solids
25 degrees Celsius
251degrees Celsius
Slope: 0.2
Intercept: 7.8
Correlation Coefficient: 1.0
Oxygen Uptake Rate: 13.64 mg Oxygen/hr
Ambient Specific Oxygen Uptake Rate: 1.53 mg Oxygen/g/hr
Average Temperature: 25 degrees Celsius
Temperature Correction Factor: 0.783526166
Temperature Corrected Specific Oxygen Uptake Rate: 1.20 mg Oxygen/g/hr
Instructions: Enter Data in the Blue Boxes. The Calculation and the Spreadsheet execute automatically.

Jun 28 07 03:32p CITY OF mnRION 828 659 1959 p.7
Time
(minutes)
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Specific Oxygen Uptake Rate
SOUR
Facility Name: Cor enin
WQ
Biosolids Permit Number: 0015
Date: f
Digester Temperature:
Sampling Date/Time: 6-19-07 1
Sampled 8y: L. Estes
Analysis Date/Time: 6-19-07
Analyzed By: R. Carter
Sample Volume:
Total Solids:
Beginning Temperature:
End Temperature:
Dissolved oxygen Level
7
6.51
3.211
Dry Solids
grees Celsius
arees Celsius
Slope: 0.3
Intercept: 7.1
Correlation Coefficient: 1.0
Oxygen Uptake Rate: 16.97 mg Oxygen/hr
Ambient Speck Oxygen Uptake Rate: 1.89 mg Oxygen/g/hr
Average Temperature: 25 degrees Celsius
Temperature Correction Factor. 0.783526166
Temperature Corrected Specific Oxygen Uptake Rate: 1.48 mg Oxygen/g/hr
Instructions: Enter Data in the Blue Boxes. The Calculation and the Spreadsheet execute automatically.

Jun 28 07 03:32p CITY OF MRRION 828 659 1959 p.8
Time
(minutes)
0
1
2
3
4
6
7
8
9
10
11
12
13
14
15
Specific Oxygen Uptake Rate
SOUR
Facility Name
Biosolids Permit Number;
Date:
Digester Temperature:
Sampling DatelTime:
Sampled By:
Analysis Date/Time:
Analyzed By:
Sample Volume:
Total Solids:
Beginning Temperature:
End Temperature:
Dissolved Oxygen Level
4.121
1
1
illiliters
Dry Solids
agrees Celsius
agrees Celsius
Slope: 0.2
Intercept: 7.5
Correlation Coefficient: 1.0
Oxygen Uptake Rate: 14.43 mg Oxygen/hr
Ambient Specific Oxygen Uptake Rate: 1.60 mg Oxygen/g/hr
Average Temperature: 25 degrees Celsius
Temperature Correction Factor: 0.783526166
Temperature Corrected Specific Oxygen Uptake Rate: 761mg Oxygen/g/hr
Instructions: Enter Data in the Blue Boxes. The Calculation and the Spreadsheet execute automatically_

Jun 28 07 03:32p
CITY OF MRRION
828 659 1959
p.9
Time
(minutes)
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Specific Oxygen Uptake Rate
SOUR
Facility Name
Biosolids Permit Numbei
Date
Digester Temperature
Sampling Date/Time
Sampled By
Analysis Date/Time
Analyzed By
Sample Volume
Total Solids
Beginning Temperature
End Temperature
Dissolved Oxygen level
7.71
7.
4.
Corpening Creek
WQ 0019960
6/21 /2007
25
6-21-07 1230
L. Estes
6-21-07 1430
R.Carter
10001
0.88
25 c
25 c
milliliters
6 Dry Solids
egrees Celsius
egrees Celsius
Slope: 0.2
Intercept: 7.9
Correlation Coefficient: 1.0
Oxygen Uptake Rate: 12.35 mg Oxygen/hr
Ambient Specific Oxygen Uptake Rate: 1.40 mg Oxygen/g/hr
Average Temperature: 25 degrees Celsius
Temperature Correction Factor: 0.783526166
Temperature Corrected Specific Oxygen Uptake Rate:[---, 1.10 mg Oxygen/g/hr
Instructions: Enter Data in the Blue Boxes. The Calculation and the Spreadsheet execute automatically.

Jun 28 07 03:32p CITY OF MRRION 828 659 1959 p.10
Time
(minutes)
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Specific Oxygen Uptake Rate
SOUR
Facility Name
Biosolids Permit Number
Date
Digester Temperature
Sampling Date/Time
Sampled By
Analysis Date/Time
Analyzed By
Sample Volume
Total Solids
Beginning Temperature
End Temperature.
Dissolved Oxygen Level
Cor enin Creek
WQ 0019960
6/22/2007
22
6-22-07 0930
L. Estes
6-22-07 1112
R.Carter
1000
0.96
25
25
Slope: 0.3
Intercept: 7.6
Correlation Coefficient: 1.0
'nilliliters
Yo Dry Solids
iegrees Celsius
iegrees Celsius
Oxygen Uptake Rate: 15.40 mg Oxygen/hr
Ambient Specific Oxygen Uptake Rate: 1.60 mg Oxygen/g/hr
Average Temperature: 25 degrees Celsius
Temperature Correction Factor: 0.783526166
Temperature Corrected Specific Oxygen Uptake Rate: 1.26 mg Oxygen/g/hr
Instructions: Enter Data in the Blue Boxes. The Calculation and the Spreadsheet execute automatically.

ofWATFR
�O G N.0 Dont. of ENR
JUN 0 4 2007
Regional Office
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
May30,2007 -� RECOVE®
Mr. J..Robert Boyette, City Manager
City of Marion. �iUN 07 2007
P.O. Drawer 700
Marion, NC 28752 j®nal
Subject: Application No. WQ001996ASheV"10 FtOg
Request for Additional Information piter pratectiOn
City of Marion Land Application Program
Land Application of Residuals
McDowell County
Dear Mr. Boyette:
The Non -Discharge Permitting Unit has conducted a preliminary review of the subject application for permit
renewal. Additional information is required before we may continue our review. Please address the following items
no later than June 30, 2007.
On Page 8 of FORM RSCA 10-06 of your application, Alternative 1 (38% Volatile Solids Reduction —
Aerobic/Anaerobic Digestion) is selected as the method to verify Vector Attraction Reduction (VAR).
Annual compliance inspections for 2005 and 2006 have shown that the 38% reduction in volatile solids
can only be met when using samples collected at the head of the aeration basin, and compared to those
collected as the sludge exits the digester. The initial sludge sample should be collected at a point just
prior to entering the digester (not at the head of the aeration basin). It is recommended that a different
option be chosen to verify VAR, unless the 38% reduction can be shown using samples collected at the
proper locations.
Please notify both the Asheville Regional Office and the Central Office (addresses below) of your
selected method to verify sufficient Vector Attraction Reduction (VAR), along with the results of the
selected test that clearly demonstrate that it has been used on the residuals and meets the necessary
standards.
NCDENR-DWQ
Aquifer Protection Section
1636 Mail Service Center
Raleigh, NC 27699-1.636
NCDENR-DWQ
Aquifer Protection Section
2090 US Highway 70
Swannanoa, NC 28778
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 responsibility
of the applicant. In addition, any omissions made in responding to the above items may result in future requests for
additional information.
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636
Internet: http://h2o.enr.state.nc.us 2728 Capital Boulevard Raleigh, NC 27604
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper
ne
ooeorthCarolina
Natula!!y
Telephone: [phone]
Fax 1: [phone]
Fax 2: [phone]
Customer Service: [phone]

Please reference the subject application number when providing the requested information. Please note that failure to
provide this additional information on or before the above requested date may result in your application being
returned as incomplete.
If you have any questions regarding this request, please do not hesitate to contact me at [phone]. You may
also check the future status of this project online at hiip://h'o.enr.state.nc.us/bims/Reports/reportsPermits.html.
Thank you for your cooperation.
Sincerely,
P
David Goodrich, P.G.
Non -Discharge Permitting Unit
cc: iBe lyrev Price,_Winston-Salem Regional Office, Aquifer Protection Section
Robert T. Branch, Branch Residuals & Soils, LLC
Permit Application File WQ0019960

v
07

C 0
AQUIFER PROTECTION SECTION
APPLICATION REVIEW REQUEST FORM
Date: April 12, 2007
To: ® Landon Davidson, ARO-APS ❑ David May, WaRO-APS
❑ Art Barnhardt, FRO-APS ❑ Charlie Stehman, WiRO-APS '
❑ Andrew Pitner, MRO-APS ❑ Sherri Knight, WSRO-APSE
❑ Jay Zimmerman, RRO-APS
From: David Goodrich, Land Application Unit
Telephone: [phone] Fax: [phone]
E-Mail: david.goodrich(a-),ncmail.net
A. Permit Number: WQ0019960
B. Owner: City of Marion
C. Facility/Operation: Residuals 503 Land Application Program
❑ Proposed ® Existing Z Facility ® Operation
D. Application:
1. Permit Type: ❑ Animal ❑ Surface Irrigation ❑ Reuse ❑ H-R Infiltration
❑ Recycle ❑ I/E Lagoon ❑ GW Remediafion (ND)
❑ UIC - (5QW) closed loop water only geothermal
For Residuals: ® Land App. ❑ D&M ❑ Surface Disposal
® 503 ❑ 503 Exempt ❑ Animal
2. Project Type: ❑ New ❑ Major Mod. ❑ Minor Mod. ❑ Renewal ® Renewal w/ Mod.
E. Comments/Other Information: ❑ I would like to accompany you on a site visit.
Statutory Date: 612 71O 7
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within 30 calendar days, please take the following actions:
® Return a Completed Form APSSRR.
❑ Attach Well Construction.Data Sheet.
❑ Attach Attachment B for Certification by the LAPCU.
❑ Issue an Attachment B Certification from the RO*.
* Remember that you will be responsible for coordinating site visits, reviews, as well as additional
information requests with other RO-APS representatives in order to prepare a complete Attachment B for
certification. Refer to the RPP SOP for additional detail.
When you receive this request form, please write your name and dates in the spaces below, make a copy
of this sheet, and return it to the appropriate Central Office -Aquifer Protection Section contact person
listed above.
f r�
RO-APS Reviewer: �r. _i'`—'� Date:
FORM: APSARR 02/06 Page 1 of 1

Central Files: APS SWP
04/12/07
Permit Number W00019960 Permit Tracking Slip
Program Category Status Project Type
Non -discharge In review Renewal
Permit Type Version Permit Classification
Land Application of Residual Solids (503) A Individual
Primary Reviewer
david.goodrich
Permitted Flow.
Facilit
Permit Contact Affiliation
J Boyette
PO Drawer 700
Marion NC -28752
Facility Name Major/Minor Region
City of Marion Residuals Land Application Program Minor Asheville
i
Location. Address County
PO Drawer 700 McDowell
Marion NC 28752 Facility Contact Affiliation
Owner Name Owner Type
City of Marion Government - Municipal
Owner Affiliation
J Boyette
PO Drawer 700.
Marion NC 28752
Dates/Events
Scheduled
Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration
01 /10/01 03/30/07
Regulated Activities Requested/Received Events
Wastewater treatment and disposal RO staff report received
RO 'staff report requested
Outfall NULL
Waterbody Name Stream Index Number Current Class Subbasin

O�OF W ArFRQG Michael F. Easley, Governor
William G. Ross Jr., Secretary
�- North Carolina Department of Environment and Natural Resources
p ��� Alan W. Klimek, P.E. Director
Division of Water Quality
April 12, 2007
J. Robert Boyette
City of Marion
P.O. Drawer 700
Marion, NC 28752
Subject: Acknowledgement of Application No. WQ0019960
City of Marion Residuals Land Application Program
Land Application of Residual Solids (503)
McDowell County
Dear Mr. Boyette:
The Aquifer Protection Section of the Division of Water Quality (the Division) acknowledges receipt of
your permit application and supporting materials on March 30, 2007. This application package has been
assigned the number listed above and will be reviewed by David Goodrich.
The reviewer will perform a detailed review and contact you with a request for additional information if
necessary. To ensure the maximum efficiency in processing permit applications, the Division requests
your assistance in providing a timely and complete response to any additional information requests.
Please be aware that the Division's Regional Office, copied below, must provide recommendations prior
to final action by the Division. Please also note at this time, processing permit applications can take as
long as 60 - 90 days after receipt of a complete application. To check on the status of your application,
You can visit littii:Hh2o.enr.state.nc.us/bims/reports/reportsPermits.litm].
If you have any questions, please contact David Goodrich by phone at [phone] or by email at
[e-mail]. If the reviewer is unavailable, you may leave a message and they will
respond promptly. Also note that the Division has reorganized. To review our new organizational chart,
go to http://h2o.enr.state.nc.us/documents/dwq_or ehart.pdf.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES
ON THIS PROJECT.
Sincerely,
,2� z
for Kim H. Colson, P.E.
Supervisor
cc: Asl7e Ile Reortal�O�ffaeeAquierjPio`.tection Section
APS Central Files - Application No. WQ0019960
Branch Residuals & Soils, LLC one
NorthCarolina
Naturally
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Telephone: [phone]
Internet: www.ncwaterguality.org Location: 2728 Capital Boulevard Raleigh, NC 27604 Fax 1: [phone]
Fax 2: [phone]
An Equal OpportuniV/Affirmative Action Employer- 50% Recycled110% Post Consumer Paper Customer Service: [phone]

T AQUIFER M, I'ECTI®N REGiONAL S'_ - _FF REPORT -Y
FILE CU
Date: 5/11/07 County: McDowell
To: Aquifer Protection Central Office Permittee:City of Marion
Central Office Reviewer: David Goodrich Project Name:Land Application of Residual Solids
Regional Login No: Application No.:W00019960
L GENERAL INFORMATION
1. This application is (check all that apply): ❑ New ® Renewal
❑ Minor Modification ® Major Modification
❑ Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
N Land Application of Residuals ❑ Attachment B included ® 503 regulated ❑ 503 exempt
❑ Distribution of Residuals ❑ Surface Disposal
❑ Closed -loop Groundwater Remediation ❑ Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare this report? ® Yes or ❑ No.
a. Date of site visit: 3/22/07 Annual Compliance Inspection; 5/10/07 Field Site Visit
b. Person contacted and contact information: Larry Carver, WWTP ORC 828-652-8843
c. Site visit conducted by: Beverly Price
d. Inspection Report Attached: ® Yes or ❑ No.
2. Is the following information entered into the BIMS record for this application correct?
❑ Yes or ® No. If no, please complete the following or indicate that it is correct on the current application.
For Treatment Facilities:
a. Location: 3982 Hwy. 226 S Marion, NC 28752
b. Driving Directions: From Asheville: Exit 86 from I-40 turn left onto Hwy. 226 S. WWTP is located
approximately 3/4 mile on the right.
c. USGS Quadrangle, Map name and number: Marion East, NC El 1NW
d. Latitude: correct in BIMS Longitude: correct in BIMS
e. Regulated Activities / Type of Wastes (e.g., subdivision, food processing, municipal wastewater): correct in
BIMS
For Disposal and Injection Sites:
(If multiple sites either indicate which sites the information applies to, copy and paste a new section into the
document for each site, or attach additional pages for each site
a. Location(s): James Fisher F-1
b. Driving Directions: From Marion: Take Hwy. 226 S to Dysartsville, continue to Dairy Rd. (SR 1771) on
the left. Fields are located approximately `/2 mile on the right after the road turns to gravel.
c. USGS Quadrangle Map name and number: Dysartsville, NC E11SE
d. Latitude: 35° 35' 39" Longitude:81° 51' 04"
a. Location(s): James Fisher F-2
b. Driving Directions: From Marion: Take Hwy. 226 S to Dysartsville, continue to Dairy Rd. (SR 1771) on
the left. Fields are located approximately'`/2 mile on the right after the road turns to gravel.
c. USGS Quadrangle Map name and number:: Dysartsville, NC El I SE
FORM: WQ0019960StaffReportV.doc 1

AQUIFER PI _ TECTI®N REGIONAL S'-t tiFF REPORT
d. Latitude: 35' 35' 32" Longitude: 81' 50' 60"
a. Location(s): James Fisher F-3
b. Driving Directions: From Marion: Take Hwy. 226 S to Dysartsville, continue to Dairy Rd. (SR 1771) on
the left. Fields are located approximately %Z mile on the right after the road turns to gravel.
c. USGS Quadrangle Map name and number:: Dysartsville, NC E11SE
d. Latitude: 35' 35' 33" Longitude: 81' 50' 42"
a. Location(s): James Fisher F-4
b. Driving Directions: From Marion: Take Hwy. 226 S to Dysartsville, continue to Dairy Rd. (SR 1771) on
the left. Fields are located approximately % mile on the right after the road turns to gravel.
c. USGS Quadrangle Map name and number: Dysartsville, NC E11SE
d. Latitude: 35' 35' 31" Longitude: 81' 50' 36"
a. Location(s): Nancy Hice Ross R-01
b. Driving Directions: From Marion: Take Hwy. 226 S to Dysartsville, continue to Walker Rd. (SR 1775) on
the right. Fields are located on both sides of the road approximately 1 mile out walker road.
c. USGS Quadrangle Map name and number: Dysartsville, NC E11 SE
d. Latitude: 35' 34' 40" Longitude: 810 51' 24"
a. Location(s): Nancy Hice Ross R-02
b. Driving Directions: From Marion: Take Hwy. 226 S to Dysartsville, continue to Walker Rd. (SR 1775) on
the right. Fields are located on both sides of the road approximately 1 mile out walker road.
c. USGS Quadrangle Map name and number: Dysartsville, NC E11SE
d. Latitude: 35' 34' 50" Longitude: 810 51' 20"
a. Location(s): Anna Sindoni-Deebold, Mario DeLuca Farm K-01
b. Driving Directions: From Marion: Take Hwy. 226 S to Dysartsville, continue to Walker Rd. (SR 1775) on
the right. Continue to Pierce Road (SR 1776) on the right. Fields are located on both sides of the road
approximately 1.5 miles out Pierce Road.
c. USGS Quadrangle Map name and number: Dysartsville, NC E11SE
d. Latitude: 35' 34' 43" Longitude:81° 51' 48"
a. Location(s): Anna Sindoni-Deebold, Mario DeLuca Farm K-02
b. Driving Directions: From Marion: Take Hwy. 226 S to Dysartsville, continue to Walker Rd. (SR 1775) on
the right. Continue to Pierce Road (SR 1776) on the right. Fields are located on both sides of the road
approximately 1.5 miles out Pierce Road.
c. USGS Quadrangle Map name and number:: Dysartsville, NC E11SE
d. Latitude: 35' 34' 43" Longitude: 81' 51' 58"
FORM: WQ0019960StaffReport07.doc 2

: AQUIFER Play f ECTI®N REGIONAL S -- SF REPORT
II. NEW AND MAJOR MODIFICA TIONAPPLICA TIONS (this section not needed for renewals or minor
modifications, skip to next section)
Description Of Waste(S) And Facilities
1. Please attach completed rating sheet. Facility Classification: Land Application
2. Are the new treatment facilities adequate for the type of waste and disposal system?
❑ Yes ❑ No ® N/A. If no, please explain:
3. Are the new site conditions (soils, topography, depth to water table, etc) consistent with what was reported by
the soil scientist and/or Professional Engineer? ® Yes ❑ No ❑ N/A. If no, please explain:
4. Does the application (maps, plans, etc.) represent the actual site (property lines, wells, surface drainage)?
Yes ❑ No ❑ N/A. If no, please explain:
5. Is the proposed residuals management plan adequate and/or acceptable to the Division. ® Yes ❑ No ❑
N/A. If no, please explain:
6. Are the proposed application rates for new sites (hydraulic or nutrient) acceptable?
® Yes ❑ No ❑ N/A. If no, please explain:
7. Are the new treatment facilities or any new. disposal sites located in a 100-year floodplain?
❑ Yes ® No ❑ N/A. If yes, please attach a map showing areas of 100-year floodplain and please explain
and recommend any mitigative measures/special conditions in Part IV:
8. Are there any buffer conflicts (new treatment facilities or new disposal sites)? ❑ Yes or ® No. If yes, please
attach a map showing conflict areas or attach any new maps you have received from the applicant to be
incorporated into the permit:
9. Is proposed and/or existing groundwater monitoring program (number of wells, frequency of monitoring,
monitoring parameters, etc.) adequate? ❑ Yes ❑ No ® N/A. Attach map of existing monitoring well
network if applicable. Indicate the review and compliance boundaries. If No, explain and recommend any
changes to the groundwater monitoring program:
10. For residuals, will seasonal or other restrictions be required? ❑ Yes ® No ❑ N/A If yes, attach list of sites
with restrictions (Certification B?)
III RENEWAL AND MODIFICATIONAPPLICATIONS (use previous section for new or major modification
systems)
Description Of Waste(S) And Facilities N/A
1. Are there appropriately certified ORCs for the facilities? ❑ Yes or ❑ No.
FORM: WQ0019960StaffReport07.doc 1 3

AQUIFER MuTEC'I'I®N REGIONAL S'iAFF REPORT '
Operator in Charge: Certificate #:
Backup- Operator in Charge: Certificate #:
2. Is the design, maintenance and operation (e.g. adequate aeration, sludge wasting, sludge storage, effluent
storage, etc) of the treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No.
If no, please explain:
3. Are the site conditions (soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ❑ No. If no, please explain:
4. Has the site changed in any way that may affect permit (drainage added, new wells inside the compliance
boundary, new development, etc.)? If yes, please explain:
5. Is the residuals management plan for the facility adequate and/or acceptable to the Division?
❑ Yes or ❑ No. If no, please explain:
6. Are the existing application rates (hydraulic or nutrient) still acceptable? ❑ Yes or ❑ No. If no, please
explain:
7. Is the existing groundwater monitoring program (number of wells, frequency of monitoring, monitoring
parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well network if
applicable. Indicate the review and compliance boundaries. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Will seasonal or other restrictions be required for added sites? ❑ Yes ❑ No ❑ N/A If yes, attach list of sites
with restrictions (Certification B?)
9. Are there any buffer conflicts (treatment facilities or disposal sites)? ❑ Yes or ❑ No. If yes, please attach a
map showing conflict areas or attach any new maps you have received from the applicant to be incorporated
into the permit:
10. Is the description of the facilities, type and/or volume of waste(s) as written in the existing permit correct? ❑
Yes or ❑ No. If no, please explain:
11. Were monitoring wells properly constructed and located? ❑ Yes or ❑ No ❑ N/A. If no, please explain:
12. Has a review of all self -monitoring data been conducted (GW, NDMR, and NDAR as applicable)? ❑ Yes or
❑ No ❑ N/A. Please summarize any findings resulting from this review:
13. Check all that apply: ❑ No compliance issues; ❑ Notice(s) of violation within the last permit cycle; ❑
Current enforcement action(s) ❑ Currently under SOC; ❑ Currently under JOC; ❑ Currently under
moratorium. If any items checked, please explain and attach any documents that may help clarify
answer/comments (such as NOV, NOD etc):
14. Have all compliance dates/conditions in the existing permit, (SOC, JOC, etc.) been complied with? ❑ Yes
❑ No ❑ Not Determined ❑ N/A.. If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑
Yes or ❑ No ❑ N/A. If yes, please explain:
FORM: WQ0019960StaffReport07.doc 4

AQUIFER PRuTECTION REGIONAL STAFF REPORT `
IV. INJECTION WELL PERMIT APPLICATIONS (Complete these two sections for all systems that use injection
wells, including closed -loop groundwater remediation effluent injection wells, in situ remediation injection wells, and heat
pump injection wells.)
Description Of Well(S) And Facilities — New, Renewal, And Modification
1. Type of injection system:
❑ Heating/cooling water return flow (5A7)
❑ Closed -loop heat pump system (5QM/5QW)
❑ In situ remediation (5I)
❑ Closed -loop groundwater remediation effluent injection (5L/"Non-Discharge")
❑ Other (Specify:
2. Does system use same well for water source and injection? ❑ Yes ❑ No
3. Are there any potential pollution sources that may affect injection? ❑ Yes ❑ No
What is/are the pollution source(s)? What is the distance of the infection well(s) from the pollution
source(s)? ft.
4. What is the minimum distance of proposed injection wells from the property boundary? ft.
5. 'Quality of drainage at site: ❑ Good ❑ Adequate ❑ Poor
6. Flooding potential of site: ❑ Low ❑ Moderate ❑ High
7. For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ❑ Yes ❑ No. Attach
map of existing monitoring well network if applicable. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Does the map presented represent the actual site (property lines, wells, surface drainage)? ❑ Yes or ❑ No. If
no or no map, please attach a sketch of the site. Show property boundaries, buildings, wells, potential pollution
sources, roads, approximate scale, and north arrow.
Injection Well Permit Renewal And Modification Only:
1. For heat pump systems, are there any abnormalities in heat pump or injection well operation (e.g. turbid water,
failure to assimilate injected fluid, poor heating/cooling)?
❑ Yes ❑ No. If explain:
2. For closed -loop heat pump systems, has system lost pressure or required make-up fluid since permit issuance
or last inspection? ❑ Yes ❑ No. If yes,
3. For renewal or modification of groundwater remediation permits (of any type), will
continued/additional/modified injections have an adverse impact on migration of the plume or management of
the contamination incident? ❑ Yes ❑ No. If yes, plain:
4. Drilling contractor: Name:
FORM: ' WQ0019960StaffReport07.doc 6

AQUIFER PRkj fECTION REGIONAL S1 OFF REPORT
Address:
Certification number:
5. Complete and attach Well Construction Data Sheet.
FORM: WQ0019960StaffReportO7.doc

AQUIFER PRMECTION REGIONAL STAFF REPORT
V. EVALUATIONAND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.: TCLP data reviewed for 2004
2005 2006 — no exceedences noted Alternative 1 (38% Volatile Solids Reduction — Aerobic/Anaerobic
Digestion) is selected as the method to verify Vector Attraction Reduction (VAR). Annual compliance
inspections for 2005 & 2006 have shown that the 38% reduction in volatile solids can only be met when using
samples collected at the head of the aeration basin and as the sludge exits the digester. The initial sludge
sample should be collected at a point just prior to enteringthe he digester. It is recommended that a different
option be chosen to verify VAR unless the 38% reduction can be shown using samples collected at the proper
locations With the exception of the residence located at 129 Pierce Rd buffer waivers were not requested for
the remaining residences adjacent to Marion DeLuca Fields K-01 & K-02 which is a change from the
Attachment B certified on 7/12/05 The new buffer map does appear to include the 400'buffer
2. Attach Well Construction Data Sheet - if needed information is available
3. Do.you foresee any problems with issuance/renewal of this permit? ❑ Yes ® No. If yes, please explain
briefly.
4. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item Reason
VAR Determiniation Permittee does not appear to be able to meet the
38% reduction.
5. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure
that you provide a reason for each condition:
Condition Reason
6. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition Reason
FORM: WQ0019960StaffReport07.doc

d
AQUIFER PRE TECTION REGIONAL SI �FF REPORT
7. Recommendation: ® Hold, pending receipt and review of additional information by regional office; ❑ Hold,
pending review of draft permit by regional office; ® Issue upon receipt of needed additional information; ❑
Issue; ❑ Deny. If deny, please state reasons:
Signature of report prepare
Signature of APS regional
Date: I C ' p...
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: WQ0019960StaffReportO7.doc

F z 7,T 4- J0g0 III )Ot V 6130%7 �3,ao Acr;ey
AQUIFER PI��TECTION REGIONAL SFF REPORT
Date:1-2-0 7 .
To: Aquifer Protection Central Office
Central Office Reviewer:
Regional Login No:
County: fl- -0o L11'(I
Permittee:C, � J A"" '-
Project Name: Pes`du
Application No.:WQ L. AG, v
L GENERAL INFORMATION
1. This application is (check all that apply): [] New 5d Renewal
[� Minor Modification ❑ Major Modification
❑ Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
[ Land Application of Residuals ❑ Attachment B included 503 regulated ❑ 503 exempt
❑ Distribution of Residuals ❑ Surface Disposal
❑ Closed -loop Groundwater Remediation ❑ Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare -this report? N Yes or ❑ No.
a. Date of site visit: Anntc4,1 Car^P�+d��C� �nS �c-`�� Dry 31 Z2/0-7 Ti e(k Sj�
P vtSo �
b. Person contacted and contact information: L&I-1 Ca KV&-, D �cw lr�T S_� 8- 4 5a - V'13
c. Site visit conducted by: B"w price-
d. Inspection Report Attached: [Yes or ❑ No.
2.- Is the following information entered into the BIMS record for this application correct?
❑ Yes or ❑ No. If no, please complete .the following or indicate that it is correct on the current application.
For Treatment Facilities: IV
g� S�
0 Location:
b. Driving Directions: Pron�,
i.Ullt'TP irk �c:ca�eti �lN mi�� bat ►^�
911 USGS Quadrangle Map name and number: fyy.k4o,) 0"s t j\T E/1 pIW
d. Latitude: W Longitude:
S � tl / g,l '77 9.
e.eguaed Activities /Type oWastes (e.g., subdivision, food processing, municipal wastewater):
For Disposal and Injection Sites: r-3 l l.,q Hc.-�S 7-j 6' 613 A
(Tf m„ltinle cites either indicate which sites the information annlies to. conv and haste a new section into the
document for each site or attach -
additional pages for each site) mod) �ec1 (v Ada !, g rgcrLS
C � Location(s):3fir Pg8$ 8. mQr1O� NC
a$Z 5T
b. Driving Directions: 14vii 4 S �no�. �Q^ 1" Dai"� 1 �-e�F� 4'e
WUSGS Quadrangle Map name and numbe I I SU."
d. Latitude: Longitude:
3`�o 351 33$f° 601 4 far. Q@F�,e �- (� �J TmM �+I
,>7, � / `�4
IL NEWAND MAJOR MODIFICATIONAPPLICATIONS (this section not needed for renewals or minor
modifications, skip to next section
Description Of Waste(S) And Facilities
1. Please attach completed rating sheet. Facility Classification: Alz�:6�� G/,Ut
2. Are the new treatment facilities adequate for the type of waste and disposal system?
FORM: APRSR040929.doe 1

P.
AQUIFER PROTECTION REGIONAL STAFF REPORT
❑ Yes ❑ No f� N/A. If no, please explain:
3. Are the new site conditions (soils, topography, depth to water table, etc) consistent with what was reported by
the soil scientist and/or Professional Engineer? � Yes ❑ No ❑ N/A. If no, please explain:
4. Does the application (maps, plans, etc.) represent the actual site (property lines, wells, surface drainage)?
Yes ❑ No ❑ N/A. If no, please explain:
5. Is the proposed residuals management plan adequate and/or acceptable to the Division. ❑ Yes ❑ No [V
N/A. If no, please explain:
6. Are the proposed application rates for new sites (hydraulic or nutrient) acceptable?
Yes ❑ No ❑ N/A. If no, please explain:
7. Are the new treatment facilities or any new disposal sites located in a 100-year floodplain?
❑ Yes X No ❑ N/A. If yes, please attach a map showing areas of 100-year floodplain and please explain
and recommend any mitigative measures/special conditions in Part IV:
8. Are there any buffer conflicts (new treatment facilities or new disposal sites)? ❑ Yes or Co No. If yes, please
attach a map showing conflict areas or attach any new maps you have received from the applicant to be
incorporated into the permit:
9. Is proposed and/or existing groundwater monitoring program (number of wells, frequency of monitoring,
monitoring parameters, etc.) adequate? ❑ Yes ❑ No N N/A. Attach map of existing monitoring well
network if applicable. Indicate the review and compliance boundaries. If No, explain and recommend any
changes to the groundwater monitoring program:
10. For residuals, will seasonal or other restrictions be required? ❑ YeSN No ❑ N/A If yes, attach list of sites
with restrictions (Certification B?)
III. RENEWAL AND MODIFICATIONAPPLICATIONS (use previous section for new or major modification
systems)
Description Of Waste(S) And Facilities N/A
1. Are there appropriately certified ORCs for the facilities? ❑ Yes or ❑ No.
Operator in Charge: Certificate #:
Backup- Operator in Charge: r Certificate M
2. Is the design, maintenance and operation (e.g. adequate aeration, sludge wasting, sludge storage, effluent
storage, etc) of the treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No.
If no, please explain:
3. Are the site conditions (soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ❑ No. If no, please explain:
FORM: APRSR040929.doc 2

r
AQUIFER PRO TECTION REGIONAL S'rAFF REPORT
4. Has the site changed in any way that may affect permit (drainage added, new wells inside the compliance
boundary, new development, eta.)? If yes, please explain:
5. Is the'residuals management, plan for the facility adequate and/or acceptable to the Division?
❑ Yes or ❑ No. If no, please explain:
6. Are the existing application rates (hydraulic or nutrient) still acceptable? ❑ Yes or ❑ No. If no, please
explain:
7. Is the existing groundwater monitoring program (number of wells, frequency of monitoring, monitoring
parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well network if
applicable. Indicate the review and compliance boundaries. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Will seasonal or other restrictions be required for added sites? ❑ Yes ❑ No ❑ N/A If yes, attach list of sites
with restrictions (Certification B?)
9. Are there any buffer conflicts (treatment facilities or disposal sites)? ❑ Yes or ❑ No. If yes, please attach a
map showing conflict areas or attach any new maps you have received from the applicant to be incorporated
into the permit:
10. Is the description of the facilities, type and/or volume of waste(s) as written in the existing permit correct? ❑
Yes or ❑ No. If no, please explain:
11. Were monitoring wells properly constructed and located? ❑ Yes or ❑ No ❑ N/A. If no, please explain:
12. Hasa review of all self -monitoring data been conducted (GW, NDMR, and NDAR as applicable)? ❑ Yes or
❑ No ❑ N/A. Please summarize any findings resulting from this review:
13. Check all that apply: ❑ No compliance issues; ❑ Noti.ce(s) of violation within the last permit cycle; . ❑
Current enforcement action(s) ❑ Currently under SOC; ❑ Currently under JOC; ❑ Currently under
moratorium. If any items checked,, please explain and attach any documents that may Help clarify
answer/comments (such as NOV, NOD etc):
14. Have all compliance dates/conditions in the existing permit, (SOC, JOC, etc.) been complied with? ❑ Yes
-❑ No ❑ Not Determined ❑ N/A.. If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑
Yes or ❑ No ❑ N/A. If yes, please explain:
FORM: APRSR040929.doc ' 3

AQUIFER PROTECTION REGIONAL STAFF REPORT
IV. INJECTION WELL PERMIT APPLICATIONS (Complete these two sections for all systems that use injection
wells, including closed -loop groundwater remediation effluent injection wells, in situ remediation injection wells, and heat
pump injection wells.)
Description Of Well(S) And Facilities — New, Renewal, And Modification
1. Type of injection system:
❑ Heating/cooling water return flow (5A7)
❑ Closed -loop heat pump system (5QM/5QW)
❑ In situ remediation (5I)
❑ Closed -loop groundwater remediation effluent injection (5L/"Non-Discharge")
❑ Other (Specify:
2. Does system use same well for water source and injection? ❑ Yes ❑ No
3. Are there any potential pollution sources that may affect injection? ❑ Yes ❑ No
What is/are the pollution source(s)? What is the distance of the injection well(s) from the pollution
source(s)? ft.
4. What is the minimum distance of proposed injection wells from the property boundary? ft.
5. Quality of drainage at site: ❑ Good ❑ Adequate ❑ Poor
6. Flooding potential of site: ❑ Low ❑ Moderate ❑ High
7. For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ❑ Yes ❑ No. Attach
map of existing monitoring well network if applicable. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Does the map presented represent the actual site (property lines, wells, surface drainage)? ❑ Yes or ❑ No. If
no or no map, please attach a sketch of the site. Show property boundaries, buildings, wells, potential pollution
sources, roads, approximate scale, and north arrow.
Injection Well Permit Renewal And Modification Only:
1. For heat pump systems, are there any abnormalities in heat pump or injection well operation (e.g. turbid water,
failure to assimilate injected fluid, poor heating/cooling)?
❑ Yes ❑ No. If yes, explain:
2. For closed -loop heat pump systems, has system lost pressure or required make-up fluid since permit issuance
or last inspection? ❑ Yes ❑ No. If yes, explain:
3. For renewal or modification of groundwater remediation permits (of any type), will
continued/additional/modified injections have an adverse impact on migration of the plume or management of
the contamination incident? ❑ Yes ❑ No. If yes, plain:
4. Drilling contractor: Name:
FORM: APRSR040929.doc 4

AQUIFER Pk%j TECTION REGIONAL S4 AFF REPORT
Address'.
5. Complete and attar Mell Construction Data Sheet.
C, lL 0-asS
Qn9 Aos5 R- 0
11
Lti C,dAl ®�
CS Ls GS Qtz6 rr.&p vi
3g010 1 O _ 4Ic-51f dLq Jody+
TIC S/ o /4//4
�Op
aL&J C-);- C an w �, S 1777
FORM: APRSR040929.doc 5

AQUIFER PROTECTION REGIONAL STAFF REPORT
V. EVALUATIONAND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.:
2. Attach Well Construction Data Sheet - if needed information is available
3. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ❑ No. If yes, please explain
briefly.
4. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item Reason
5. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure
that you provide a reason for each condition:
Condition Reason
6. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition Reason
7. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office; ❑ Hold,
pending review of draft permit by regional office; ❑ Issue upon receipt of needed additional information; ❑
Issue; ❑ Deny. If deny, please state reasons:
8. Signature of report preparer(s):
Signature of APS regional supervisor:
Date:
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: APRSR040929.doc 6

���J pG
6
5 _ _
J. Robert Boyette, City Manager
City of Marion
Post Office Drawer 700
Marion, NC 28752
Dear Mr. Boyette:
North Carolina Dept
OPY
AQUIFER PROTECTION
April 2, 2007
Michael F. Easley, Governor
William G. Ross Jr., Secretary
of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Asheville Regional Office
SUBJECT: March 22, 2007 Compliance
Evaluation Inspection City of Marion
City of Marion Residuals Land Application
Program
Permit No: WQ0019960
McDowell County
Enclosed please find a copy of the Compliance Evaluation Inspection form from the
inspection conducted on March 22, 2007. The facility was found to be in Compliance with
permit WQ0019960.
The 2006 Annual Report was reviewed as part of the inspection. The soils report did
not include the Exchangeable Sodium Percentage (ESP) calculation. Three copies of the
ESP should be submitted to the following address within 10 days of receipt of this letter:
NC Department of Environment & Natural Resources
Division of Water Quality
Information Processing Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Attn: Ed Hardee
Fields R-17 F-01 and F-02 indicated a pH below optimum levels with a recommendation
for the addition of lime. Lime was not added in 2006 according to Mr.
Soil Builders. If the soils report indicates the need for lime, it should
year as the land application event.
Zack Key with Southern
be applied in the same
,XOne NhCarolina
atarall!l
North Carolina Division of Water Quality — Asheville Regional Office 2090 U.S. Highway 70 Swannanoa, NC 28778 Phone [phone]
Aquifer Protection Section FAX [phone]
Customer Service 1-877-623-6748
Internet: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer — 50% Recycled110% Post Consumer Paper

Mr. Boyette
April 2, 2007
Page 2
In addition, The 2006 Annual Report indicated Option One (38% Volatile Solids (VS)
Reduction) was used to verify Vector Attraction Reduction (VAR) requirements. The VS
calculation showed samples were collected at the influent to the aeration basin and the sludge
digester. Although the "White House Manual" does not dictate the start point for measuring
volatile solids, it does suggest the appropriate comparison is between the sewage sludge
entering the digester and the sewage sludge leaving the digester. It is recommended that you
use the waste sludge entering the digester for your initial VS sludge calculation. If the 38%
reduction cannot be met using Option One, then you should consider other options. Please
refer to the 'White House Manual" for additional information regarding other VAR options.
Please refer to the enclosed inspection report (Inspection Summary Page 2) for
additional observations and comments. If you or your staff has any questions, please call me
at 828-296-4500.
Sincerely, ,/0,1
Beverly Price
Environmental Specialist
Enclosure
cc: Larry Carver, WWTP ORC
Dennis Key, Zack Key, ORC's Southern Soil Builders
Aquifer Protection Central Files
tAquiffer�Pr�o@tecti©n■Ashe t

Permit: WQ0019960
SOC:
County: McDowell
Region: Asheville
Compliance Inspection Report
Effective: 07/12/05 Expiration: 06/30/06 Owner: City of Marion
Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
PO Drawer 700
Contact Person: J Robert Boyette
Directions to Facility:
Primary ORC: Dennis Key
Secondary ORC(s):
David W Key
On -Site Representative(s):
On -site representative
24 hour contact name
Related Permits:
Inspection Date: 03/22/2007
Primary Inspector: Beverly Price
Secondary Inspector(s):
Larry Dean Carver
Larry Dean Carver
Entry Time: 10:00 AM
Marion NC 28752
Phone: [phone]
Certification: 15704
Certification: 23629
Exit Time: 12:00 PM
Phone: [phone]
Phone: [phone]
Phone: [phone]
Phone: [phone]
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: 0 Compliant Q Not Compliant
Question Areas:
Miscellaneous Questions 1§ Record Keeping Treatment Sampling
jj Land Application Site ® Pathogen and Vector ® Transport
Attraction
(See attachment summary)
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 03/22/2007 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Land application was occurring on Fisher Fields #03 & 04. Southern Soil Builders administers the land application
program for the City of Marion. The land application event appeared to be conductd according to permit conditions.
A review of the 2006 Annual Report was also included in the inspection. The following issues were noted with regard to
the '06 Annual Report: 1) Several parameters were missing from the TCLP analysis - missing parameters were obtained
during the inspection. 2) VAR - Operatonal data was missing -- operational data was obtained during the inspection.
Option 1 (38% VS Reduction) was chosen for verification of VAR -- bench sheets for volatile solids calculations showed
that samples for comparison were collected at the influent to the aeration basin and the digester. The appropriate
comparison is between sludge entering the digester and the sewage sludge leaving the digester. 3) Fields R-1, F-01,
F-02 indicated a need for lime -- lime was not added in '06. Lime recommendations should be followed during the year in
which land application occurred. 4) Parameters missing from soils report: Cu, Zn, Mn and Exchangeable Sodium
Perecntage(ESP) -- Cu, Zn & Mn obtained during the inspection. ESP should be submitted.
Permit expired 6/30/06. Mr. Bob Branch (Branch Residuals & Soils) has contacted the Central Office concerning
submission of renewal application.
Page: 2

Permit: W00019960 Owner - Facility: City of Marion
Inspection Date: 03/21/2007 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Type
Yes
No
NA
NE
Distribution and Marketing
❑
Land Application
Im
Record Kee -}ling
Yes
No
NA
NE
Is GW monitoring being conducted, if required?
❑
❑
®
Cl
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?
®
n
n
n
a. TCLP analysis?
®
n
❑
n
b. SSFA (Standard Soil Fertility Analysis)?
❑
❑
❑
Are PAN balances being maintained?
❑
❑
❑
Are PAN balances within permit limits?
®❑
❑
❑
Has land application equipment been calibrated?
n
n
n
IM
Are there pH records for alkaline stabilization?
❑
Cl
®
❑
Are there pH records for the land application site?
®❑
n
n
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?
®
Cl
❑
❑
Has application occurred during Seasonal Restriction window?
❑
❑
®
❑
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)
❑
❑
is
❑
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 03/21/2007 Inspection Type: Compliance Evaluation
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)
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench -top Aerobic/Anaerobic digestion results
Comment:
Treatment
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Comment:
Reason for Visit: Routine
■
n
n
n
n
n
n
Sampling Yes
No
NA
NE
Describe sampling:
Samples are collected from two different spots in the digester, then composited for TCLP and metals
analyses. Samples for fecal coliform analyses are collected over a 2-3 week period from different points in the
digester.
Is sampling adequate? ■
Q
Q
0
Is sampling representative? ■
❑
❑
❑
Comment:
Transport Yes
No
NA
NE
Is a copy of the permit in the transport vehicle? ■
Q
n
Page: 4

Permit: WO0019960 Owner - Facility: City of Marion
Inspection Date: 03/21/2007 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Is a copy of the spill control plan in the vehicle?
Is the spill control plan satisfactory? ®❑ ❑
Does transport vehicle appear to be maintained? ®❑ ❑
Comment:
Land Application Site
Yes
no
NA
NI
Is a copy of the permit on -site during application events?
O
❑
Is the application site in overall good condition?
®
n
n
n
Is the site free of runoff/ponding?
®
n
n
n
If present, is the application equipment in good operating condition?
®
❑
❑
Q
Are buffers being maintained?
a
n
n
In
Are limiting slopes buffered?
10% for surface application
M
0
❑
n
18% for subsurface application
❑
n
®
❑
Are there access restrictions and/or signs?
®
In
n
n
Is the application site free of odors or vectors?
o
o
n
Have performance requirements for application method been met?
For injection?
❑
n
®
O
For incorporation?
n
Does permit require monitoring wells?
n
is
n
Have required MWs been installed?
❑
0
®
n
Are MWs properly located w/ respect to RB and CB?
❑
❑
®
n
Are MWs properly constructed (including screened interval)?
n
D
®
❑
Is the surrounding area served by public water?
n
®n
n
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
❑
n
Are soil types consistent w/ Soil Scientist report/evaluation?
n
n
Cl
Is the water table greater than 173' bls.
Q
Q
n
Is application occurring at the time of the inspection?
®
n
❑ ❑
Comment: Surrounding area is not served by public water.
Page: 5

Compliance Inspection Report
Permit: WO0019960 Effective: 07/12/05 Expiration: 06/30/06 Owner: City of Marion
SOC: Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
County: McDowell PO Drawer 700
Region: Asheville
Marion NC 28752
Contact Person: J Robert Boyette Phone: [phone]
Directions to Facility:
Primary ORC: Dennis Key Certification: 15704 Phone: [phone] em
7g7$-
Secondary ORC(s):
David W Key Certification: 23629 Phone: [phone]
ISO -C-6I1
On -Site Representative(s):
On -site representative Larry Dean Carver Phone: [phone]
24 hour contact name Larry Dean Carver Phone: [phone]
Related Permits:
Inspection Date: GW217T007 Entry Time:-4030 _AM Exit Time: 12:30 PM
Primary Inspector: Beverly Price Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment ® Sampling
Land Application Site Pathogen and Vector Transport
Attraction
(See attachment summary) r'1 J e-w j o Ce .
Ask 7- �
PO .
�ro m
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 03/21/2007 Inspection Type: Compliance Evaluation
Inspection Summary:
�{o Irt l-e 3 v54
P--9 �.
3C.Il-,y
971
C LC
c©Upy-
It &,Jj/ an-d
Reason for Visit: Routine
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 03/21/2007 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Record Keeping
Yes No
NA
NE
Is GW monitoring being conducted, if required?
❑ ❑
M
❑
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?
W ❑
❑
❑
Are current metals and nutrient analysis available? t©`a
1 ❑
❑
❑
Are nutrient and metal loading calculating most limiting parameters?
0 ❑
❑
❑
a. TCLP analysis?
Is ❑
❑
❑
b. SSFA (Standard Soil'Fertility Analysis)? Wib'6- �o��, � ��
❑ ❑
❑
❑
Are PAN balances being maintained? 0L .,
yt5 104 ❑ ❑
Q
❑
Are PAN balances within permit limits? ''\%,L , ,
145 �b ❑ ❑
❑
Cl
Has land application equipment been calibrated? -�'�, ���a v i<4'
❑
/❑
❑
op
Are there pH records for alkaline stabilization?
❑
a
❑
Are there pH records for the land application site?
IR- ❑
❑
❑
Are nutrient/crop removal practices in place? ryNa:A , A+S ��S e
4' ❑
❑
❑
Do lab sheets support data reported on Residual Analysis Summary? FDA '0`1 y�5 r
'04 ❑ ❑
❑
'in
Are hauling records available?
Is ❑
❑
❑
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? '
❑ ❑
a
❑
Comment:
Pathogen and Vector Attraction
Yes No
NA
NE
/
a. Fecal coliform SM 9221 E (Class A or B) 9;0 C/�
9
❑
❑
❑
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)
❑ ❑
10
❑
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)
0090
c. pH records for alkaline stabilization (Class B)
❑ ❑
0
❑
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 03/21/2007 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Temperature corrected n
d. Salmonella (Class A, all test must be < 3MPN/4 gram day) ❑- ❑ La
e. Time/Temp on:
❑❑W0
Digester (MCRT)
n
Compost
Class A lime stabilization
f. Volatile Solids Calculations p , Y_ - VOL" W1aeK �'�r- Ve A nnvA= Rom° l J Rollo
L� t?e✓d C�uring la-1 ` t�v c�'on2 Co. etc.
g. Bench -top Aerobic/Anaerobic digestion results Cmcv_0=410%'� `'16 VS �e�ucs�i� fl n
�„� no � S ✓n6w 3$
Comment: its T•,
Treatment Sho�kl �NAU fotp`-, collar✓' Yes No NA NE
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
n
Alkaline Stabilization (Class B)
n
Compost
n
Drying Beds
n
Other
❑
Comment:
Sampling �all� Fi �1"
y
-cr—
Yes
No
NA
NE
w P QJ��
Describe sam lin Q.n-P105 1' �"` das
P 9
i ©d
a=3
i-�eats sp�z�l o CvA
Is sampling adequate? Ml( �«
Is sampling representative?
+
n
❑
Comment:
Transport
Yes
No
NA
NE
Is a copy of the permit in the transport vehicle?
0111111
Is a copy of the spill control plan in the vehicle?
H
n
❑
Is the spill control plan satisfactory?
0000
Does transport vehicle appear to be maintained?
n
n
n
Comment:
Page: 4

Permit: WO0019960 Owner - Facility: City of Marion
Inspection Date: 03/21/2007 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Land_ Application Site
Yes No
NA
NE
Is a copy of the permit on -site during application events?
W ❑
Cl
❑
Is the application site in overall good condition?
0 ❑
❑
❑
Is the site free of runoff/ponding?
❑
❑
❑
If present, is the application equipment in good operating condition?
Im ❑
❑
❑
Are buffers being maintained?
M ❑
❑
❑
Are limiting slopes buffered?
10% for surface application
12 ❑
❑
❑
18% for subsurface application
❑ ❑
N
0\
Are there access restrictions and/or signs?
K ❑
❑
❑ .
Is the application site free of odors or vectors?
19 ❑
Cl
❑
Have performance requirements for application method been met?
For injection?
❑ ❑
❑
For incorporation?
❑ ❑
❑
Does permit require monitoring wells?
n
n
❑
Have required MWs been installed?
❑ ❑
❑
Are MWs properly located w/ respect to RB and CB?
❑ ❑
_ R
❑
Are MWs properly constructed (including screened interval)?
❑ 119
❑
Is the surrounding area served by public water?
❑ B
❑
❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
❑ ❑
0
❑
Are soil types consistent w/ Soil Scientist report/evaluation?
❑ ❑
❑
jo
Is the water table greater than 173' bls. c kec,k Ce,4. '13
❑ ❑
❑
Is application occurring at the time of the inspection?
❑
❑
❑
Comment:
Page:. 5

47.
In
ftt�
--------------

3-16
JvL6 C/6
IMM

Re: City of Marion Land Application Permit W00019960
Subject: Re: City of Marion Land Application Permit WQ0019960
From: Ed Hardee <[e-mail]>
Date: Fri, 09 Jun 2006 11:50:07 -0400
To: Bob Branch <[e-mail]>
CC: Bev Price <[e-mail]�-
Bob Branch wrote:
I Ed and Bev,
As we have discussed previously, the City of Marion's land application permit is scheduled to expire
June 30, 2006. This was just brought to my attention and I would request an extension until
September 30, 2006 to get every thing together for the renewal and possibly modification. I do not
currently see where getting this put together by that time frame should be a problem. Thanks for your
help and respond back with your decision.
Bob Branch
Bob,
I am ok with the extension. The City of Marion's renewal will be due September 30, 2006.
Ed Hardee
Land Application Unit
F
of 1 8/31/2006 7:48 AM

FILE COPY
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Deparnnent of Environment and Natural Resources
AQUIFER PROTECTION
June 20, 2006
J. Robert Boyette, City Manager
City of Marion
Post Office Drawer 700
Marion, NC 28752
Alan W. Klimek, P.E. Director
Division of Water Quality
SUBJECT: June 6, 2006
Compliance Evaluation Inspection
City of Marion
Permit No: WQ0019960
McDowell County
Dear Mr. Boyette:
Enclosed please find a copy of the Compliance Evaluation Inspection form from the inspection conducted
on June 6, 2006. The facility was found to be in Compliance with permit WQ0019960.
2005 Annual Report Review:. The 2005 Annual Report indicated Option One (38% Volatile Solids (VS)
Reduction) was used to verify Vector Attraction Reduction (VAR) requirements. Two VS calculations were
submitted, one from the WWTP influent and the other from the Return . Activated Sludge (RAS). The VS
calculation for the RAS did not show a 38% reduction while the WWTP, influent did show a 38% reduction.
Although the "White House Manual does not dictate the start point for measuring volatile solids it does suggest
the appropriate comparison is between the sewage sludge entering the digester and the sewage sludge leaving
the digester. In your case the 38% reduction was a comparison between the influent wastewater entering the
plant and the sludge leaving the digester. It is recommended that you use the RAS or waste activated sludge for
future VS calculations. If the 38% reduction cannot be met using Option One you should consider Option Three
or Four. Please refer to the "White House Manual' for additional information regarding other VAR options.
Please refer to the enclosed inspection report for additional observations and comments. If you or your
staff has any questions, please call me at [phone].
Sincerely
p,'[\ /J J
Ytfi �!' ��✓ vc� �L
Beverly Price
Environmental Specialist
Enclosure
cc: Dennis Key, ORC Southern Soil Builders
Larry Carver, WWTP ORC
APS Central Files
One
13-'-rA3B i IeB No Carolina
Ntcrrally
North Carolina Division of Water Quality — Asheville Regional Office 2090 U.S. Highway 70 Swannanoa, NC 28778 Phone [phone]
Aquifer Protection Section FAX [phone]
Customer Service 1-877-623-6748
Internet: h2o,enr.state.nc,us
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

Compliance Inspection Report
Permit: WQ0019960 Effective: 07/12/05 Expiration:.06/30/06 Owner: City of Marion
SOC: Effective: Expiration: Facility- City of Marion Residuals Land Application
Program
County: McDowell PO Drawer 700
Region: Asheville
Marion NC 28752
Contact Person: J Robert Boyette Phone: [phone]
Directions to Facility:
Primary ORC: Dennis Key
Secondary ORC(s):
David W Key
On -Site Representative(s):
24 hour contact name
Related Permits:
Inspection Date: 06/06/2006
Primary Inspector: Beverly Price
Secondary Inspector(s):
Certification: 15704
Certification: 23629
Larry Dean Carver
Phone: [phone]
Phone: [phone]
Phone: [phone]
Entry Time: 09:30 AM Exit Time: 11:30 AM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ■ Compliant 11 Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment Sampling
Land Application Site ■ Pathogen and Vector ■ Transport
Attraction.
(See attachment summary)
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 06/06/2006 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The inspection consisted of a tour of the land application site and a records review including the 2005 Annual Sludge
Report. Land application was occurring on Wayne Ross Field R-1. The field is restricted by fencing. Southern Soil
Builders (SSB) is the contract operator for land application activities for the Town of Marion. SSB appears to be doing a
good job of land applying residuals for the Town of Marion.
2005 Annual Report: Two volatile solids(VS)calculations were given. The VS calculations from the RAS did not show a
38% reduction. VS calculations from the influent sample did show a 38% reduction.
Two sets of metals data were submitted: The first data set showed Molybdenum at 67 mg/kg. The second data set
showed Molybdenum at 92 mg/kg. Laboratory report indicated Molybdenum was retested on 10114/05. 10/14/05 results
showed 42 mg/kg.
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 06/06/2006 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type Yes No NA NE
Distribution and Marketing ❑
Land Application
Record Keeping
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?
Comment:
Pathogen and Vector Attraction
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 CFLI/dry gram
Fecal coliform SM 9222 D (Class B only)
■
Yes No NA NE
■❑❑❑
❑'.
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 06/06/2006 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
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)
n
n
■
C. pH records for alkaline stabilization (Class B)
n
n
■
❑
Temperature corrected
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
❑
❑
■
n
❑
rl
■
e. Time/Temp on:
Digester (MCRT)
n
Compost
n
Class A lime stabilization
f. Volatile Solids Calculations
■
El
n
n
g. Bench -top Aerobic/Anaerobic digestion results
❑
❑
■
n
Comment:
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:
Sampling
Describe sampling:
Fecal samples are collected over a two -week period at seven different locations in the digester. Metals and
nutrient samples are also collected from the digester. Four to five samples are collected and composited for
analysis.
Is sampling adequate?
Is sampling representative?
Comment:
Transport
Is a copy of the permit in the transport vehicle?
■
n
n
n
n
n
n
■nnn
■nnn
Page: 4

Permit: WO0019960 Owner - Facility: City of Marion
Inspection Date: 06/06/2006 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Is a copy of the spill control plan in the vehicle?
■
❑
❑
❑
Is the spill control plan satisfactory?
■
❑
❑
0
Does transport vehicle appear to be maintained?
■
❑
❑
❑
Comment:
Land Application Site
Yes
No
NA
NE
Is a copy of the permit on -site during application events?
■
❑
❑
❑
Is the applicationsite in overall good condition?
■
rl
❑
n
Is the site free of runoff(ponding?
■
❑
❑
❑
If present, is the application equipment in good operating condition?
■
❑
❑
❑
Are buffers being maintained?
■
❑
❑
❑
Are limiting slopes buffered?
10% for surface application
■
❑
❑
❑
18% for subsurface application
❑
❑
■
❑
Are there access restrictions and/or signs?
■
❑
❑
❑
Is the application site free of odors or vectors?
■
❑
❑
❑
Have performance requirements for application method been met?
For injection?
❑
❑
■
❑
For incorporation?
❑
❑
■
❑
Does permit require monitoring wells?
❑
■
❑
❑
Have required MWs been installed?
❑
❑
■
❑
Are MWs properly located w/ respect to RB and CB?
❑
❑
■
❑
Are MWs properly constructed (including screened interval)?
❑
❑
■
❑
Is the surrounding area served by public water?
❑
■
❑
❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
❑
❑
■
❑
Are soil types consistent w/ Soil Scientist repo rl/evaluation?
❑
❑
❑
■
Is the water table greater than 1 Y3' bls.
❑
❑
■
❑
Is application occurring at the time of the inspection?
■
❑
❑
❑
Comment: MWs are not required.
Page: 5

Permit: VVQ0019960
SOC:
County: McDowell
Region: Asheville
Compliance Inspection Report
Effective: 07/12/05 Expiration: 06/30/06 Owner: City of Marion
Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
PO Drawer 700
Contact Person: J Robert Boyette
Directions to Facility:
�' Iz
Primary ORC: nnis y�"�
Secondary ORC(s):
On -Site Representative(s):
24 hour contact name
Related Permits:
Inspection Date: 06/06/2006
Primary Inspector: Beverly Price
Secondary Inspector(s):
Larry Dean Carver
Entry Time: 09:30 AM
Marion NC 28752
Phone: [phone]
Certification: 15704
Exit Time: 11:30 AM
Phone: [phone]
Phone: [phone]
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
® Miscellaneous Questions ® Record Keeping ® Treatment ■ Sampling
® Land Application Site ® Pathogen and Vector ® Transport
Attraction
(See attachment summary)
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 06/06/2006 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 06/06/2006 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type Yes No NA NE
Distribution and Marketing n
Land Application ■
Record Keeping
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?
c?�- I ,��Y N �xl,�ef¢
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis? �, 91P,4, - �
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
,Are PAN balances within permit limits? ps
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? &hp7.1t4
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 12months?
Has application occurred during Seasonal Restriction window?
Comment:
Pathogen and Vector Attraction i
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)
nn■n
nn■n
nn■n
nn■n
i�nnn
Pnnn
wnnn
Bnnn
�nnn
�,nnn
�nnn
i�nnn
nn1n
�nnn
�rnnn
�nnn
1&nnn
0nnn
IN n n n
n*n
Yes No NA NE
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 06/06/2006 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Geometric mean of 7 samples per monitoring period for class B<2.0'10E6 CFU/dry gram
n
b. pH records for alkaline stabilization (Class A)
n
n
La
n
c. pH records for alkaline stabilization (Class B)
❑
❑
ING,
❑
Temperature corrected
n
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
❑
❑
95
❑
e. Time/Temp on:
n
n
Go
Digester (MCRT)
n
Compost
n
Class A lime stabilization
n
f. Volatile Solids Calculations
n
n
n
g. Bench -top Aerobic/Anaerobic digestion results
❑
n
Comment:
Treatment
Yes
No
NA
NE
Check all that apply
Aerobic Digestion
Anaerobic Digestion
n
Alkaline Pasteurization (Class A)
n
Alkaline Stabilization (Class B)
n
Compost
Drying Beds
n
Other
n
Comment:
i
e Vn C�'���
Yes
No
NA
NE
Describe sampling: fzeAS— 2�'
Is sampling adequate?
n
n
n
Is sampling representative?
n
n
n
Comment:
Transport
Yes
No
NA
NE
Is a copy of the permit in the transport vehicle?
0
n
n
n
Is a copy of the spill control plan in the vehicle?
a
n
n
n
Page: 4

19 ro ( _e�
Permit: WQ0019960 Owner -Facility: City of Marion Al
Inspection Date: 06/06/2006 Inspection Type: Compliance Evaluation LJ Dgi° Reason for Visit: Routine
57.3�
Is the spill control plan satisfactory? �3� n n , n
Does transport vehicle appear to be maintained?
Comment:
Land Application Site
Is a copy of the permit on -site during application events?
Is the application site in overall good condition?
Is the site free of runoff/ponding?
If present, is the application equipment in good operating condition?
Are buffers being maintained?
Are limiting slopes buffered?
10% for surface application
18% for subsurface application
Are there access restrictions and/or signs? —one,&d
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MVVs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
/ le_ PJL Yes No NA NE
JPnnn
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluatioh?
Is the water table greater than 1'/3' bls. ,
Is application occurring at the time of the inspection?
Comment: bLkf- '
ROSS rr_SAe,,c 2 mar-e- S 4cd e 2�
�Innn
�innn
�nnn
0000
Page: 5

OF W ATF
Michael G
William G. Ross Jr., Secretary
r North Carolina Department of Environment and Natural Resources
—i
Alan W. Klimek, P.E. Director
Division of Water Quality
Aquifer Protections
All �y
August 22, 2005 <' .
Mr. J. Robert Boyette'`j
City Manager
City of Marion
Post Office Drawer 700
Marion, North Carolina 28752
Subject: Letter of Comment
2004 Annual Report
City of Marion
Land Application of Residual Solids (503)
Permit No. WQ0019960
McDowell County
Dear Mr. Boyette:
The Asheville regional office_ has completed a review of your 2004 Annual Report. The report indicates you have chosen
Alternative 1 as the method to meet the Pathogen Reduction requirement. In addition, you have chosen Aerobic Digestion
as a "Process to Significantly Reduce Pathogens" (PSRP). There is no need to indicate a PSRP if Alternative 1 is
chosen. If you wish to select the PSRP Aerobic Digestion, then Alternative 2 should be checked on the certification form
and you should submit the appropriate operational time/temperature data. Additionally, you have selected Option 1(at
least 38% reduction in volatile solids during sewage sludge treatment) to satisfy the Vector Attraction Reduction
requirements. Your records indicate that volatile suspended solids were used to determine the 38% reduction. The
volatile solids calculations should be based on total solids rather than suspended solids. It is recommended that you get
a copy of the EPA Guidance Document Environmental Regulations and Technology Control of Pathogens and Vector
Attraction in Sewage Sludge (the "White House Manual") if you do not have one. The web site for this document is
www.epa.gov/ORD/NRMRL. The document number is 625/R-92/013.
If you should have any questions regarding this matter, please do not hesitate to contact me at [phone].
Sincerely,
Beverly Price
Environmental Specialist
Cc: Larry Carver, WWTP ORC
Dennis Key, Land Application ORC Southern Soil Builders 958 Hoots Road Roaring, River, NC 28669
One
NorthCaroli na
�'1?aturally
North Carolina Division of Water Quality — Asheville Regional Office 2090 U.S. Highway 70 Swannanoa, NC 28778 Phone [phone]
Aquifer Protection Section FAX [phone]
Customer Service 1-877-623-6748
Intemet: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer— 50% Recycledl10% Post Consumer Pager

Michael F.Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Aquifer Protection
August 22, 2005
Mr. J. Robert Boyette
City Manager
City of Marion
Post Office Drawer 700
Marion, North Carolina 28752
Subject: Letter of Comment
2004 Annual Report
City of Marion
Land Application of Residual Solids (503)
Permit No. W00019960
McDowell County
Dear Mr. Boyette:
The Asheville regional office has completed a review of your 2004 Annual Report. The report indicates you have chosen
Alternative 1as the method to meet the Pathogen Reduction requirement. In addition, you have chosen Aerobic Digestion
as a "Process to Significantly Reduce Pathogens (PSRP). There is no need to indicate a PSRP if Alternative 1 is
chosen. If you wish to select the PSRP Aerobic Digestion, then Alternative 2 should be checked on the certification form
and you should submit the appropriate operational time/temperature data. Additionally, you have selected Option 1(at
least 38% reduction in volatile solids during sewage sludge treatment) to satisfy the Vector Attraction Reduction
requirements. Your records indicate that volatile suspended solids were used to determine the 38% reduction. The
volatile solids calculations should be based on total solids rather than suspended solids. It is recommended that you get
a copy of the EPA Guidance Document Environmental Regulations and Technology Control of Pathogens and Vector
Attraction in Sewage Sludge (the "White House Manual") if you do not have one. The web site for this document is
www.epa.gov/ORD/NRMRL. The document number is 625/R-92/013.
If you should have any questions regarding this matter, please do not hesitate to contact me at [phone].
Sincerely,
Beverly Price
Environmental Specialist
Cc: Larry Carver, WWTP ORC
Dennis Key, Land Application ORC Southern Soil Builders 958 Hoots Road Roaring River, NC 28669
One NCarolina
Natumllry
North Carolina Division of Water Quality — Asheville Regional Office 2090 U.S. Highway 70 Swannanoa, NC 28778 Phone [phone]
Aquifer Protection Section FAX [phone]
Customer Service 1-877-623-6748
Internet: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
June 23, 2005
MR. J. ROBERT BOYETTE, CITY MANAGER
CITY OF MARION
POST OFFICE DRAWER 700
MARION, NORTH CAROLINA 28752
Subject: Application No. WQ0019960
Additional Information Request
City of Marion
City of Marion Residuals Land Application Program
Land Application of Residuals (503)
McDowell County
Dear Mr. Boyette:
The Aquifer Protection Section of the Division of Water Quality's (Division) Asheville Regional Office has
completed a detailed review of the above -referenced permit modification application package. At this time, additional
information is required before we may continue our review.
Be aware that you are responsible for meeting all requirements set forth in the North Carolina rules and
regulations. Any oversights that occurred in the review of this permit modification application package are still the
responsibility of the applicant. In addition, any omissions made in responding to the requested additional information
request items may result in further additional information requests and delays in the certification of a modified
Attachment B. Therefore, read each requested item carefully, and provide the information that is requested as well as any
information that results from changes made as a result of this additional information request. If there is any question
about what additional information is being requested or is desired, please contact me at any time, and I will be happy to
provide additional explanation as required.
Please address the following item no later than July 23, 2005:
During the site visit performed by the Aquifer Protection Section of the Division's Asheville Regional Office, it
was noted that stream restoration work was being performed along the western boundaries of Frank Queen Site
Nos. Q-10, Q-15, and Q-16. Please clarify whether or not it is still desired to seek approval of these sites for
incorporation into this residuals land application program. It especially appears as if Site No. Q-10 would be
rendered unsuitable for residuals land application from additional buffers resulting from the restored stream.
However, if approval is still desired, the Division is prepared to approve each of these sites; however, their use
will be conditioned with the following requirement:
"At the time of approval of this modified Attachment B, stream restoration work was being performed
along the western boundary of this land application site. It was uncertain how this work would affect the
proposed application area. If the currently -approved application area of this site changes as a result of
this work, an amended buffer map and net acreage for this site shall be submitted to the Division at least
45 calendar days prior to the initiation of any residuals land application activities on this site. Only
following review and approval of these amended documents may residuals land application activities
North Carolina Division of Water Quality— Asheville Regional Office 2090 U.S. Highway 70 Swannanoa, NC 28778 Phone [phone]
Aquifer Protection Section FAX [phone]
Customer Service 1-877-623-6748
Internet: h2o.enr.state.nc.us
o ehCarolina
NNaturally
An Equal Opportunity/Affirmative Action Employer— 50% Recycledl10% Post Consumer Paper

Mr. Boyette
June 23, 2005
Page 2
occur on this site. Submit two copies of any amended buffer map and net acreage values to the
NCDENR-DWQ, Aquifer Protection Section, Land Application Unit, c% LAUResiduals Program
Coordinator, 1636 Mail Service Center, Raleigh, NC 2709-1636. "
Please comment on whether the Division's proposal is acceptable.
Please reference the subject application number when providing the requested additional information. Four
copies of all revised information should be submitted to my attention at the address on the first page of this
correspondence.
If you have any questions regarding this additional information request, please do not hesitate to contact me by
telephone at [phone], extension 4665, or via e-mail at [e-mail]. Thank you in advance for your
cooperation and assistance.
Sincerely,
Beverly Price
Environmental Specialist
cc: Bob Branch, Branch Residuals & Soils, LLC 311 B South Westgate Greensboro, North Carolina 27407
Asheville Regional Office - Aquifer Protection Section Files
e�i�Appii-eation■alexW..- OQ•ALlr9960

AQUIFER PROTECTION REGIONAL SZ AFF REPORT
Date: 6/17/2005 County: McDowell
To: Aquifer Protection Central Office Permittee: City of Marion
Central Office Reviewer: Shannon Thornburiz Project Name:
Regional Login No: Application No.: W00019960
L GENERAL INFORMATION
1. This application is (check all that apply): ❑ New ® Renewal
❑ Minor Modification ❑ Major Modification
❑ Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
® Land Application of Residuals ® Attachment B included ® 503 regulated ❑ 503 exempt
❑ Distribution of Residuals ❑ Surface Disposal
❑ Closed -loop Groundwater Remediation ❑ Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare this report? ® Yes or ❑ No.
a. Date of site visit: 06/17/2005
b. Person contacted and contact information: Larry Carver, ORC City of Marion WWTP 828-652-8843
c. Site visit conducted by: Bev Price, Shannon Thornburg, Bob Branch
d. Inspection Report Attached: ❑ Yes or ® No.
2. Is the following information entered into the BIMS record for this application correct?
❑ Yes or ❑ No. If no, please complete the following or indicate that it is correct on the current application.
For Treatment Facilities: F, (Po e,L� JC �d � t '5 q/ �
a. Location:
3S I,Sa�/ %1 5'�1,�9j 3S39.575�
b. Driving Directions: f
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude: g / 6r
e. Regulated Activities / Type of Wastes (e.g., subdivision, food processing, municipal wastewater):
For Disposal and Injection Sites:
(If multiple sites either indicate which sites the information applies to copy and paste a new section into the
document for each site or attach additional pages for each site) J 6/ �(
�' {--t a3 �nG�✓P0��7"� C,- r`� L C
a. Location(s): fr�� Qu-e�
b. Driving Directions: la I, 9 V os� �/a " l
A
c. USGS Quadrangle Map name and number:
39.97rp
d. Latitude: Longitude:
d�
GD�, o„ ICI- I 51.97�
✓^ ,C
IL NEWAND MAJOR MODIFICATIONAPPLICATIONS this section not needed fof renewals or minor
modifications, skip to next section) j � Glc/ 90
3�_ 39./0/ o gl S/, StS8-
Description Of Waste(S) And Facilities 419� 111f/� n
Curn- Jlo al /L1
1. Please attach completed rating sheet. Facility Classification:
2. Are the new treatment facilities adequate for the type of waste and disposal system?
F. 4�22r Fi4 a� `JS 39 ,°2� Do SI.,!�-y�
FORM: WQ0019960 StaffReport05.doc 1 nn_I 6� 6 ,1U
pdt�n �f� n.. 1 `

AQUIFER PROTECTION REGIONAL STAFF REPORT
❑ Yes ❑ No ❑ N/A. If no, please explain:
3. Are the new site conditions (soils, topography, depth to water table, etc) consistent with what was reported by
the soil scientist and/or Professional Engineer? ❑ Yes ❑ No ❑ N/A. If no, please explain:
4. Does the application (maps, plans, etc.) represent the actual site (property lines, wells, surface drainage)? ❑
Yes ❑ No ❑ N/A. If no, please explain:
5. Is the proposed residuals management plan adequate and/or acceptable to the Division. ❑ Yes ❑ No ❑
N/A. If no, please explain:
6. Are the proposed application rates for new sites (hydraulic or nutrient) acceptable?
❑ Yes ❑ No ❑ N/A. If no, please explain:
7. Are the new treatment facilities or any new disposal sites located in a 100-year floodplain?
❑ Yes ❑ No ❑ N/A. If yes, please attach a map showing areas of 100-year floodplain and please explain
and recommend any mitigative measures/special conditions in Part IV:
8. Are there any buffer conflicts (new treatment facilities or new disposal sites)? ❑ Yes or ❑ No. If yes, please
attach a map showing conflict areas or attach any new maps you have received from the applicant to be
incorporated into the permit:
9. Is proposed and/or existing groundwater monitoring program (number of wells, frequency of monitoring,
monitoring parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well
network if applicable. Indicate the review and compliance boundaries.. If No, explain and recommend any
changes to the groundwater monitoring program:
10. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ N/A If yes, attach list of sites
with restrictions (Certification B?)
IIL RENEWAL AND MODIFICATIONAPPLICATIONS (use previous section for new or maior modification
systems)
Descriution Of Waste(S) And Facilities
1. Are there appropriately certified ORCs for the facilities? ❑ Yes or ❑ No.
Operator in Charge: Certificate #:
Backup- Operator in Charge: Certificate #:
2. Is the design, maintenance and operation (e.g. adequate aeration, sludge wasting, sludge storage, effluent
storage, etc) of the treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No.
If no, please explain:
3. Are the site conditions (soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ❑ No. If no, please explain:
FORM: WQ0019960 StaffReport05.doc 2

AQUIFER PROTECTION REGIONAL STAFF REPORT
4. Has the site changed in any way that may affect permit (drainage added, new wells inside the compliance
boundary, new development, etc.)? If yes, please explain:
5. Is the residuals management plan for the facility adequate and/or acceptable to the Division?
❑ Yes or ❑ No. If no, please explain:
6. Are the existing application rates (hydraulic or nutrient) still acceptable? ❑ Yes or ❑ No. If no, please
explain:
7. Is the existing groundwater monitoring program (number of wells, frequency of monitoring, monitoring
parameters, etc.) adequate? ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well network if
applicable. Indicate the review and compliance boundaries. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Will seasonal or other restrictions be required for added sites? ❑ Yes ❑ No ❑ N/A If yes, attach list of sites
with restrictions (Certification B?)
9. Are there any buffer conflicts (treatment facilities or disposal sites)? ❑ Yes or ❑ No. If yes, please attach a
map showing conflict areas or attach any new maps you have received from the applicant to be incorporated
into the permit:
10. Is the description of the facilities, type and/or volume of waste(s) as written in the existing permit correct? ❑
Yes or ❑ No. If no, please explain:
11. Were monitoring wells properly constructed and located? ❑ Yes or ❑ No ❑ N/A. If no, please explain:
12. Has a review of all self -monitoring data been conducted (GW, NDMR, and NDAR as applicable)? ❑ Yes or
❑ No ❑ N/A. Please summarize any findings resulting from this review:
13. Check all that apply: ❑ No compliance issues; ❑ Notice(s) of violation within the last permit cycle; ❑
Current enforcement action(s) ❑ Currently under SOC; ❑ Currently under JOC; ❑ Currently under
moratorium. If any items checked, please explain and attach any documents that may help clarify
answer/comments (such as NOV, NOD etc):
14. Have all compliance dates/conditions in the existing permit, (SOC, JOC, etc.) been complied with? ❑ Yes
❑ No ❑ Not Determined ❑ N/A.. If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑
Yes or ❑ No ❑ N/A. If yes, please explain:
FORM: WQ0019960 StaffReport05.doc 3

AQUIFER PROTECTION REGIONAL STAFF REPORT
IT. INJECTION WELL PERMIT APPLICATIONS (Complete these two sections for all systems that use injection
wells, including closed -loop groundwater remediation effluent injection wells, in situ remediation injection wells, and heat
pump injection wells.)
Description Of Well(S) And Facilities — New, Renewal, And Modification
1. Type of injection system:
❑ Heating/cooling water return flow (5A7)
❑ Closed -loop heat pump system (5QM/5QW)
❑ In situ remediation (5I)
❑ Closed -loop groundwater remediation effluent injection (5L/"Non-Discharge")
❑ Other (Specify:
2. Does system use same well for water source and injection? ❑ Yes ❑ No
3. Are there any potential pollution sources that may affect injection? ❑ Yes ❑ No
What is/are the pollution source(s)? What is the distance of the injection well(s) from the pollution
source(s)? ft.
4. What is the minimum distance of proposed injection wells from the property boundary? ft.
5. Quality of drainage at site: ❑ Good ❑ Adequate ❑ Poor
6. Flooding potential of site: ❑ Low ❑ Moderate ❑ High
7. For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ❑ Yes ❑ No. Attach
map of existing monitoring well network if applicable. If No, explain and recommend any changes to the
groundwater monitoring program:
S. Does the map presented represent the actual site (property lines, wells, surface drainage)? ❑ Yes or ❑ No. If
no or no map, please attach a sketch of the site. Show property boundaries, buildings, wells, potential pollution
sources, roads, approximate scale, and north arrow.
Iniection Well Permit Renewal And Modification Only:
1. For heat pump systems, are there any abnormalities in heat pump or injection well operation (e.g. turbid water,
failure to assimilate injected fluid, poor heating/cooling)?
❑ Yes ❑ No. If yes, explain:
2. For closed -loop heat pump systems, has system lost pressure or required make-up fluid since permit issuance
or last inspection? ❑ Yes ❑ No. If yes, explain:
3. For renewal or modification of groundwater remediation permits (of any type), will
continued/additional/modified injections have an adverse impact on migration of the plume or management of
the contamination incident? ❑ Yes ❑ No. If yes, explain:
4. Drilling contractor: Name:
FORM: WQ0019960 StaffReport05.doc 4

AQUIFER PRuTECTION REGIONAL STAFF REPORT
Address:
Certification number:
5. Complete and attach Well Construction Data Sheet. /
�J �L-v3`0Gi1.
FORM: WQ0019960 StaffReport05.doc 5

AQUIFER PROTECTION REGIONAL STAFF REPORT
V. EVALUATIONAND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.:
2. Attach Well Construction Data Sheet - if needed information is available
3. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ❑ No. If yes, please explain
briefly.
4. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item Reason
5. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure
that you provide a reason for each condition:
Condition Reason
6. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Condition Reason
7. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office; ❑ Hold,
pending review of draft permit by regional office; ❑ Issue upon receipt of needed additional information; ❑
Issue; ❑ Deny. If deny, please state reasons:
8. Signature of report preparer(s):
Signature of APS regional supervisor:
Date:
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: WQ0019960 StaffReport05.doc 6

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William G. Ross Jr., Secretary
North Carolina Departm 'Environment and Natural Resources
rAlan W. Klimek, P.E. Director
—4 Division of Water Quality
Asheville Regional Office
AQUIFER PROTECTION
July 21, 2005
J. Robert Boyette
City Manager
City of Marion
Post Ofiice Drawer 700
Marion, NC 28752
SUBJECT: June 23, 2005 Compliance Evaluation
Inspection City of Marion
City of Marion Residuals Land Application Program
Land Application of Residuals (503)
Permit No: WQ0019960
McDowell County
Dear Mr. Boyette:
Enclosed please find a copy of the Compliance Evaluation Inspection form from -the
inspection conducted on June 23, 2005. Beverly Price of the Asheville Regional Office conducted
the Compliance Evaluation Inspection. The facility was found to be in Compliance with permit
WQ0019960.
The records appear to be complete and accurate. There was one issue with regard to the
2004 Annual Report. Two of the seven fecal coliform analyses showed greater than values. It is
recommended that the lab set dilutions 'to show discrete rather than greater than values. The
sample may need to be re -analyzed if within hold time or a second sample could be collected and
analyzed.
The assistance of Mr. Larry Carver was greatly appreciated during the inspection. Please
refer to the enclosed inspection report for additional observations and comments. If you or your
staff has any questions, please call me at 828-296-4500 Ext.4685.
Sincerely,
Beverly rice
Enclosure
cc: Dennis Key, ORC Southern Soil Builders 958 Hoots Road Roaring River, NC 28669
Larry Carver, WWTP ORC
�A_qu1f-er Protection-Seetion�Asheville--Files-•
Npne
r Carolina
iura!!�
2090 U.S. Highway 70, Swannanoa, NC 28778 Telephone: [phone] Fax: [phone] Customer Service 1 877 623-6748

Compliance Inspection Report
Permit: W00019960 Effective: 11/05/02 Expiration: 06/30/06 Owner: City of Marion
SOC: Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
County: McDowell PO Drawer 700
Region: Asheville
Contact Person: J Robert Boyette
Directions to Facility:
Primary ORC: Dennis Key
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 06/23/2005
Primary Inspector: Beverly Price
Secondary Inspector(s)
Entry Time: 11:30 AM
Marion NC 28752
Phone: [phone] Ext.
Certification: 15704
Exit Time: 01:00 PM
Phone: [phone]
Phone: [phone]
Ext.4655
Phone:
Phone:
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ■ Compliant 1:1 Not Compliant
Question Areas:
Miscellaneous Questions N Record Keeping Treatment Sampling
■ Pathogen and Vector
Attraction
Inspection Summary:
The inspection included a records review (2004) Annual Report and a tour of the residuals facilities. Land application was not
occurring at the time of inspection. Land application is handled by Southern Soil Builders.
The records appeared to be complete. Two of seven fecal samples showed greater than values. It is recommended that the lab set
dilutions to show discrete rather than greater than values. The fecal sample may need to be re -analyzed if within hold time or a
second sample could be collected and analyzed.
Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 06/23/2005 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Land Application
Yes
No
NA NE
Record Keening
Is GW monitoring being conducted, if required?
Cl ❑
M
Are GW samples from all MWs sampled for all required parameters?
C1
M ❑
Are there any GW quality violations?
❑ El
M ❑
Is GW-59A certification form completed for facility?
❑ C1
M
El
❑
Is a copy of current permit on -site?
Are current metals and nutrient analysis available?
11
El El
Are nutrient and metal loading calculating most limiting parameters?
El
❑ 13
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
❑
El ❑
Are PAN balances within permit limits?
11
❑
Has land application equipment been calibrated?
M
Are there pH records for alkaline stabilization?
11
M
Are there pH records for the land application site?
❑ El
M ❑
Are nutrient/crop removal practices in place?
11
❑ M
Do lab sheets support data reported on Residual Analysis Summary?
❑
❑
Are hauling records available?
❑ ❑
Cl M
Are hauling records maintained and up-to-date?
1:1O
O 0
Has permittee been free of public complaints in last 12 months?
M
Has application occurred during Seasonal Restriction window?
❑ ❑
0 M
Comment: Land application was occurring at the time of inspection. Nutrient/metals analyses were reviewed from the
2004 Annual Report. The 2005 sample results had not been received at the time of the inspection.
Yes No
NA NE
Pathogen and Vector Attraction
a. Fecal coliform SM 9221 E (Class A or B)
M O
❑ ❑
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)
❑ C3
M O
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)
El 1100
c. pH records for alkaline stabilization (Class B)
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
M 0
❑
g. Bench -top Aerobic/Anaerobic digestion results
11 ❑
0
Comment: Two of five fecal results showed greater than values.
Page: 2

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: 06/23/2005 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Treatment
Check all that apply
Yes No NA NE
Aerobic Digestion
Anaerobic Digestion
❑
Alkaline Pasteurization (Class A)
❑
Alkaline Stabilization (Class B)
❑
Compost
❑
Drying Beds
❑
Other
❑
Comment:
Sampling
Yes No NA NE
Describe sampling: Samples are collected at seven different points in the digester.
Is sampling adequate?
❑ ❑ ❑
Is sampling representative?
❑ ❑ ❑
Comment:
Page: 3

/ ­1 uy. vi�I 1111.,
Carolina Technical Services, Inc.
Instrumentation 5aleo, Integration, & Service
PROPOSAL
July 19, 2001
Quote No.: 2001579
Terms: See CTS "Conditions of Sale"
Delivery: 4-6 weeks ARO
City of Marion
Larry Carver
PO Box 1271
Marion, NC 28752
QTY.
DESCRIPTION
UNIT PRICE
EXTENSION
1
ATI, Inc. Single Gas Monitoring System consisting of:
4 Digit LED, sunlight readable / Isolated 4-2OmA Output /
Two adjustable concentration alarms / Three assignable
relays / Trouble alarm LED bargraph
1- B12-17-3-0100-4 Explosion Proof Sensor
1- 00-0261Remote Calibration Kit
1- B14-17-0100-4 Receiver Module
1- 80-006 Two Module Enclosure (NEMA 4X)
1- . 00-0055 Power Supply
1- 00-0058 Audible Horn
1- 35-0002 Strobe with Red Lense
Sub -Total:
$1,775.00
Tax:
$ 106.50
Shipping:
$ 10.00
TOTAL:
$1,891.50
Acceptance by
and Date:
I have read and understand the CTS' conditions of sale
P.O. Box 268. China Grove, NC 28023
Phone: [phone]
Fax: [phone]
WebSite: www.carolinateehmical.com
Purchase Order #:

Permit: WQ0019960
SOC:
County: McDowell
Region: Asheville
Compliance Inspection Report
Effective: 11/05/02 Expiration: 06/30/06 Owner: City of Marion
Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
PO Drawer 700
rLttr
Contact Person: Larrn ` W w7(- 6 2G
Directions to Facility:
Primary ORC: 1zfln' S V-9 1 S�
SecondaryORC(s):DGv11 11 J a 3
On -Site Representative(s):
Related Permits:
Inspection Date: (6-47 OS Entry Time;
Primary Inspector: Beverly Price
Secondary Inspector(s):
Certification:
Reason for Inspection: Routine
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
■ Miscellaneous Questions ■ Record Keeping ■ Treatment ■ Sampling
Marion NC 28752 a
Phone:
COO
Exit Time:
Phone: 33G
Phone: [phone]
Ext.4655
Phone:
Phone:
Inspection Type: Compliance Evaluation
■ Land Application Site ■ Pathogen and Vector ■ Storage ■ Transport
Attraction
Inspection Summary: i t-spi
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Page: 1

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: Inspection Type: Compliance Evaluation Reason for Visit: Routitie
Tyne
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?
❑
❑
®
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Is GW-59A certification form completed for facility?
❑
❑
®
❑
Is a copy of current permit on -site?
❑
❑
❑
Are current metals and nutrient analysis available? fQoh+ '0Y AAXLC( 21r
Q
❑
❑
❑
Are nutrient and metal loading calculating most limiting parameters?
iE
❑
❑
❑
a. TCLP analysis?
®
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❑
❑
b. SSFA (Standard Soil Fertility Analysis)?
®
❑
❑
❑
Are PAN balances being maintained?
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Are PAN balances within permit limits?
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Has land application equipment been calibrated?
❑
❑
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Are there pH records for alkaline stabilization?
❑
❑
®
❑
Are there pH records for the land application site?
❑
❑
91
❑
Are nutrient/crop removal practices in place?
/ � �/
❑
❑
El{
Do lab sheets support data repotted on Residual Analysis Summary?°O� s�n,P/�
reS�% �O 7
®
❑
❑
❑
Are hauling records available?
❑
❑
❑
IN
Are hauling records maintained and up-to-date?
❑
❑
❑
.0
Has permittee been free of public complaints in last 12 months?
®
❑
❑
❑
Has application occurred during Seasonal Restriction window?
It ❑
❑
Comment:
Pathogen and Vector Attraction
Yes No NA NE
a. Fecal coli form SM 9221 E (Class A or B)
Q
❑
❑
❑
Class A, all test must be <1000 MPN/dry gram
❑
Geometric mean of 7 samples per monitoring period for class B<2.0* 1 OE6 CFU/dry gram
pp
IJ o-�
Fecal coliform SM 9222 D (Class B only)
% y4&zs
�� � w[ rja `J �
❑
❑
�.
❑
Geometric mean of samples per monitoring period for class B<2.0*10E6 CFU/dry gram
y- 4- t65L Q va due- %
❑
b. pH records for alkaline stabilization (Class A)
e{a �`(L i b� �e-❑
ccnJJ�
11211
c, pH records for alkaline stabilization (Class B)
% �
IPlfS
El
El9
❑
Temperature corrected
> 1/G
o cga
❑
d. Salmonella (Class A. all test must be <3MPN/4 gram day)lni
�� nUM'
❑
❑
®
❑
e. Time/Temp on:
❑
❑
99
❑
Digester (MCRT)
❑
Compost
❑
Class A lime stabilization Sh° c �J ���
tS <<i`-t on n 4e
❑
®
❑
❑
❑
f. Volatile Solids Calculations > 3�Q1'� tee,
g. Bench -top Aerobic/Anaerobic digestion results
❑
❑
®
❑
Comment:
Treatment
Yes No
NA NE
Page: 2

• 4
Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: Inspection Type: Compliance Evaluation Reason for Visit: Routine
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Comment: A /
m
7n� Q ter/ T
es /'bo sam pling: V
s p n� g adequate?
_samp representative?
Comment:
a cop of the permit in the transportvehicle?
]sac y of the spill control plan in the vehicle?
Is t e spill c of plan satisfactory'?
oes transport vehicle appear to be maintained?
Comment:
Land Application Site '-pia /'w — to O
Is a copy of the permit on -site during application events?
Is the application site in overall good condition?
Is the site free of nmoff/ponding?
If present, is the application equipment in good operating condition?
Are buffers being maintained?
Are limiting slopes buffered?
10% for surface application
18% for subsurface application
Are there access restrictions and/or signs?
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
�_ m- W'e
IkA
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
Yes No NA NE
Yes No NA NE
No fi 6ccu�-r��
Yes No NA NE
IN
❑
110
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
ON
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑❑❑❑
❑ ❑ 9 ❑
❑❑a❑
❑ 0 ❑ ❑
❑ ❑ R ❑
❑ ❑ 90 ❑
❑ ❑ IN ❑
❑ ❑ ❑ ❑
❑ ❑ 0 ❑
❑ ❑ 1115
Page: 3

Permit: WQ0019960 Owner - Facility: City of Marion
Inspection Date: Inspection Type: Compliance Evaluation
Is the water table greater than P/3' bls.
Is application occurring at the time of the inspection?
Comment:
Reason for Visit: Routine
Page: 4

► $RANCH RESIDUALS & SOILS, LLC
311 B South Westgate Drive • Greensboro, NC 27407
PHONE [phone] FAx [phone]
July 6, 2005
C �J
Cn
S Cn
N.C. Department of Environment and Natural Resources
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Aquifer Protection Section
;�r
T a
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Asheville Regional Office
m
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2090 U.S. Highway 70
t
Swannanoa, NC 28778773
`J
rr
ATTENTION: Ms. Beverly Price
REFERENCE: City of Marion Additional Information Request
Permit No. WQ0019960
Land Application Permit
BR&S Job No. 2004-41
Dear Ms. Price:
On behalf of the City of Marion and after conversation with Mr. Larry Carver of the City of Marion,
I have prepared a response to the Addition Information Request dated June 23, 2005. During the
field review of the Frank: Queen site three fields appear to be impacted by the current stream
restoration project that is occurring adjacent to these sites. Both the City of Marion and I are in
agreement that Field Q-10 should be dropped for consideration as a receiver site from the current
modification. In addition, Fields Q-15 and Q-16 should remain in the current modification but with
the disclaimer that an amended buffer map and updated acreage for these fields 45 calendar days
prior to the initiation of land application activities.
CLOSING
Since there no modifications, just deletions, to the current modification request, I will only include
this letter. If you have any question regarding this information, please give me a call at (336) 510-
0340.
Sincerely,
Robert T. Branch; L.S.S.
Project Manger/Soil Scientist _
cc: Larry Carver — City of Marion WWTP
Bob Boyette — City of Marion

O�O� W A T �9pG
'C
MR. J. ROBERT BOYETTE, CITY MANAGER
CITY OF MARION
POST OFFICE DRAWER 700
MARION, NORTH CAROLINA 28752
Dear Mr. Boyette:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
M fj/
June 23, 2005
Subject: Application No. WQ0019960
Additional Information Request
City of Marion
City of Marion Residuals Land Application Program
Land Application of Residuals (503)
McDowell County
The Aquifer Protection Section of the Division of Water Quality's (Division) Asheville Regional Office has
completed a detailed review of the above -referenced permit modification application package. At this time, additional
information is required before we may continue our review.
Be aware that you are responsible for meeting all requirements set forth in the North Carolina rules and
regulations. Any oversights that occurred in the review of this permit modification application package are still the
responsibility of the applicant. In addition, any omissions made in responding to the requested additional information
request items may result in further additional information requests and delays in the certification of a modified
Attachment B. Therefore, read each requested item carefully, and provide the information that is requested as well as any
information that results from changes made as a result of this additional information request. If there is any question
about what additional information is being requested or is desired, please contact me at any time, and I will be happy to
provide additional explanation as required.
Please address the following item no later than July 23, 2005:
During the site visit performed by the Aquifer Protection Section of the Division's Asheville Regional Office, it
was noted that stream restoration work was being performed along the western boundaries of Frank Queen Site
Nos. Q-10, Q-15, and Q-16. Please clarify whether or not it is still desired to seek approval of these sites for
incorporation into this residuals land application program. It especially appears as if Site No. Q-10 would be
rendered unsuitable for residuals land application from additional buffers resulting from the restored stream.
However, if approval is still desired, the Division is prepared to approve each of these sites; however, their use
will be conditioned with the following requirement:
"At the time of approval of this modified Attachment B, stream restoration work was being performed
along the western bounda7y of this land application site. It was uncertain how this work would affect the
proposed application area. If the currently -approved application area of this site changes as a result of
this work, an amended buffer map and net acreage for this site shall be submitted to the Division at least
45 calendar days prior to the initiation of any residuals land application activities on this site. Only
following review and approval of these amended documents may residuals land application activities
North Carolina Division of Water Quality — Asheville Regional Office 2090 U.S. Highway 70 Swannanoa, NC 28778 Phone [phone]
Aquifer Protection Section FAX [phone]
Customer Service 1-877-623-6748
Internet: h2o.enr.state.nc.us
NorthCarolina
Naturaliy
An Equal Opportunity/Affirmative Action Employer_ 50% Recycled110% Post Consumer Paper

Mr. Boyette
June 23, 2005
Page 2
occur on this site. Submit two copies of any amended buffer map and net acreage values to the
NCDENR-DWQ, Aquifer Protection. Section, Land Application Unit, c% LAUResiduals Program
Coordinator, 1636 Mail Service Center, Raleigh, NC 27699-1636. "
Please comment on whether the Division's proposal is acceptable.
Please reference the subject application number when providing the requested additional information. Four
copies of all revised information should be submitted to my attention at the address on the first page of this
correspondence.
If you have any questions regarding this additional information request, please do not hesitate to contact me by
telephone at [phone], extension 4665, or via e-mail at [e-mail]. Thank you in advance for your
cooperation and assistance.
Sincerely,
r
Beverly Price
Environmental Specialist
cc: Bob Branch, Branch Residuals & Soils, LLC 311 B South Westgate Greensboro, North Carolina 27407
rKslM,egi-onal Office -.Aquifer Protection SEct o Files
Permit Application File WQ0019960

f
u E
gpAQUIFER
_a—1
PROTECTION SECTION F_
APPLICATION REVIEW REQUEST FORM A
�2�
Cn
MM
Date: June 1, 2005
To: ® Landon Davidson, ARO-APS �r
❑ David May, WaRO-AP
!�
❑ Art Barnhardt, FRO-APS ❑ Charlie Stehman, WiRO
�-
❑ Andrew Pitner, MRO-APS ❑ Sherri Knight, WSRO-
❑ Jay Zimmerman, RRO-APS
r
U .7
H
From: Shannon Mohr Thornburg , Land Application Permitting and Compliance Unit
Telephone: [phone] Fax: [phone] —
-------
E-Mail: [e-mail]
A. Permit Number: W00019960
B. Owner: City of Marion
C. Facility/Operation: Citv of Marion Residuals Land Application Program
❑ Proposed ® Existing ❑ Facility ® Operation
D. Application:
1. Permit Tj pe: ❑ Animal ❑ Surface Irrigation ❑ Reuse ❑ H-R Infiltration
❑ Recycle ❑ I/E Lagoon ❑ GW Remediation (ND)
❑ UIC - (5QW) closed loop water only geothermal
For Residuals: ® Land App. ❑ D&M ❑ Surface Disposal.;,
® 503 ❑ 503 Exempt ❑ Animal
2. Project Type: ❑ New ❑ Major Mod. ❑ Minor Mod. ❑ Renewal ❑ Renewal w/ Mod.
E. Comments/Other Information: ® I would like to accompany you on a site visit.
Site visit and training tentatively set-up with Bev Price on 06/17/2005
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within 30 calendar days, please take the following actions:
❑ Return a Completed Form APSARR.
❑ Attach Well Construction Data Sheet.
❑ Attach Attachment B for Certification by the LAPCU.
® Issue an Attachment B Certification from the RO*.
Remember that you will be responsible for coordinating site visits, reviews, as well as additional
information requests with other RO-APS representatives in order to prepare a complete Attachment B for
certification. Refer to the RPP SOP for additional detail.
When you receive this request form, please write your name and dates in the spaces below, make a copy
of this sheet, and return it to the appropriate Central Office -Aquifer Protection Section contact person
listed above. 0-
RO-APS Reviewer: 7z f
�� Date:
FORM: APSARR 09/04 Page 1 of 1

Central Files: APS SWP
06/01 /05
Permit Number WQ0019960
Permit Tracking Slip
Program Category
Status Project Type
Non -discharge
In review Major modification
Permit Type
Version Permit Classification
Land Application of Residual Solids (503)
Individual
Primary Reviewer
Permit Contact Affiliation
landon.davidson
J Boyette
PO Drawer 700
Permitted Flow
Marion NC 28752
Facilit
Facility Name
City of Marion Residuals Land Application
Program
Location Address
PO Drawer 700
Marion NC 28752
Owner
Owner Name
City of Marion
Dates/Events
Scheduled
Orig Issue App Received Draft Initiated Issuance
01 /10/01 05/27/05
Regulated Activities
Wastewater treatment and disposal
Outfali NULL
Major/Minor Region
Minor Asheville
County
McDowell
Facility Contact Affiliation
Owner Type
Government - Municipal'
Owner Affiliation
PO Drawer 700
Marion NC 28752
Public Notice . Issue
Waterbody Name Stream Index Number
Current Class
Effective Expiration
Subbasin

Y OF MARION
WA1_.. AND SEWER FUND
PA. DRAWER nO '
M ION, NO 8815E
PAY
BankofAmeric iQ�
27256
w1um w
DATE 6-24-61S f «�I
$ 325.E
,N
DOLLARS

O� WATj9 Michael F. Easley, Governor
/ OCR pG William G. Ross Jr., Secretary
y North Carolina Department of Environment and Natural Resources
r
=1 Alan W. Klimek, P.E., Director
`" — 'C Division of Water Quality
June 1, 2005
MR. J. ROBERT BOYETTE, CITY MANAGER
CITY OF MARION
POST OFFICE DRAWER 700
MARION, NORTH CAROLINA 28752
Subject: Application No. WQ0019960
Return of Application Fee
City of Marion
City of Marion Residuals Land Application Program
Land Application of Residual Solids (503)
McDowell County
Dear Mr. Boyette:
Please find enclosed the check for the application fee that was originally sent with the above -
referenced permit application package. The Division of Water Quality's (Division) Land Application Unit
received a new check, revised to reflect the correct application fee on May 27, 2005. This returned check may
be voided or destroyed.
Thank you for resolving this matter so quickly. If you have any questions about this
correspondence, please do not hesitate to contact me at [phone] or via e-mail - at
[e-mail].
7han
irely,
non Mohr Thornburg
Environmental Engineer II
Enclosure
cc: Mr. Robert T. Branch, L.S.S., Branch Residuals & Soils, L.L.C.
Pen -nit
o1,C
NorthCarolina
1�/Vaiur�!!�
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
Internet: http://h2o.enr.state.nc.us 2728 Capital Boulevard Raleigh, NC 27604 Fax [phone]
Fax [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recycledll0% Post Consumer Paper

V.'--VENDOR"i7. -1.].^MTE. _^�4r
CITY OF MARION WATER AND __.JER FUND 10275 4/26/2005
NCDENR- fifer Prote
:CHECK NUMBER
18471
<n INVOICENUMBER
�. INVOICE GATE
'/26/2005
%.INVOICE'M10UNT
Permit N WQO
$205.00 Perm't'renewal
6 modi
icat $205.0
Total Check: $205.00
GI 1 0 OF Itl ARIO1Y VBIOOR CONiPOL NO DATE
WATER AND SEWER FUND --
_ PD,RO%S36 - 102 5 Y8471 v�
MARION,NC 28752 /26/200
- L50B .
'Pay'Exactly:, *�*****205 Dollara'and 00 cents
j
CHECK NO,
01'8471
PMOUNT
$205.00

O� WArF9 _ Michael F. Easley, Governor
Q William G. Ross Jr., Secretary
'O'Albn
y North Carolina Department of Environment and Natural Resources
> Alan W. Klimek, P.E., Director
p Division of Water Quality
June 1, 2005
MR. J. ROBERT BOYETTE, CITY MANAGER
CITY OF MARION
POST OFFICE DRAWER 700
MARION, NORTH CAROLINA 28752
Subject: Application No. WQ0019960
Acknowledgment of Application Receipt
City of Marion
City of Marion Residuals Land Application Program
Land Application of Residual Solids (503)
McDowell County
Dear Mr. Boyette:
The Division of Water Quality's (Division) Land Application Unit acknowledges receipt of your
permit application package on May 27, 2005. This package has been assigned the permit application number
listed above and has been forwarded to Mr. Landon Davidson of the Aquifer Protection Section of the
Division's Asheville Regional Office for review and processing.
To ensure maximum efficiency in processing this package, the Division requests your assistance in
providing a timely and complete response to any additional information requests. Please note, at this time,
processing of permit application packages may take as long as 60 to 90 days after receipt of=a complete
package.
. .. PLEASE REFER TO THE PERMIT APPLICATION NUMBER WHEN MAKING
INQUIRIES REGARDING THIS PERMIT APPLICATION PACKAGE.
If you have any questions about this package, please contact Mr. Davidson of the Aquifer Protection
Section of the Division's Asheville Regional Office at [phone] or via e-mail at
[e-mail].
Thank you in advance for your cooperation and assistance.
S* rely,
lim H. Colson, P.E.
Supervisor
cc: Mr. Robert T. Branch, L.S.S., Branch Residuals & Soils, L.L.C.
Mr-L-andon`Davidson; Asheville. Regional -Office --Aquifer-Protection-Section
Permit File WQ0019960
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636
Internet: http://h2o.enr.state.nc.us 2728 Capital Boulevard Raleigh, NC 27604
o1,C
NorthCarolina
Naturally
Phone [phone] Customer Service
Fax [phone]
Fax [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper

�oF WAr, Michael F. Easley, Governor
William G. Ross Jr., Secretary
7 North Carolina Department of Environment and Natural Resources
r
=i Gregory J. Thorpe, Ph.D., Acting Director
a < Division of Water Quality
April 24, 2002
MR. J. ROBERT BOYETTE, CITY MANAGER
CITY OF MARION
POST OFFICE DRAWER 700
MARION, NORTH CAROLINA 28752
Subject: Permit No. WQ0019960
City of Marion
City of Marion Residuals Land Application Program
Land Application of Residual Solids (503)
McDowell County
Dear Mr. Boyette:
In accordance with a minor modification request from Mr. Larry Carver, Wastewater Treatment
Plant Supervisor for the City of Marion that was received by the Division of Water Quality (Division) on
February 26, 2002, we are forwarding herewith a modified Permit No. WQ0019960, dated April 24,
2002, to the City of Marion for the subject residuals land application program.
This permit shall be effective from the date of issuance until June 30, 2006; shall void Permit No.
WQ0019960, issued on July 20, 2001; and shall be subject to the conditions and limitations as specified
therein. Make note of this permit's expiration date and the fact that a permit renewal application is due to
the Division no later than six months prior to that date (i.e., see Condition VI. 7.), as the Division does not
send reminders to apply for permit renewal.
This permit is being issued to include the continued and optional operation of facilities existing at
the Corpening Creek WWTP to lime stabilize residuals. These facilities are capable of producing a Class
A residuals product, which is currently approved for marketing and distribution by the City of Marion'
under Permit No. WQ0008681. The City of Marion has decided to rescind Permit No. WQ0008681 (i.e.,
rescission process started on February 26, 2002) now that Class B land application has been approved by
the Division. However, it was desired to allow for continued operation of the lime stabilization facilities
on an as -needed basis should the required pathogen and vector attraction reduction requirement not be
met through aerobic digestion alone. Note that all residuals, even if they are lime stabilized and/or meet
Class A standards, must be land applied in strict accordance with the conditions contained in this permit.
No marketing and distribution shall be allowed once Permit No. WQ0008681 is rescinded by the
Division.
With this minor modification, the Division has taken the opportunity to reissue this permit in the
format currently being used for all residuals land application programs. This format was developed to
facilitate new application review procedures that have been put into place by the Division. Although no
substantive changes have been made to the conditions contained within this permit, the Permittee should
take the time to review this document to ensure complete familiarity and understanding of the format and
the condition language. Pay particular attention to the monitoring requirements in this permit. Failure to
establish an adequate system for collecting and' maintaining the required operational information will
result in future compliance problems..
Non -Discharge Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
DENR Customer Service Center
An Equal Opportunity Action Employer
Internet http://h2o.enr.state.nc.us/ndpu
Telephone [phone] Fax [phone]
Telephone [phone]
50% recycled/10% post -consumer paper

If any parts, requirements, and/or limitations contained in this permit are unacceptable, you have
the right to request an adjudicatory hearing upon written request within 30'days following receipt of this
permit. This request shall be in the from of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes and filed with the Office of Administrative Hearings at 6714 Mail Service
Center, Raleigh, North Carolina 27699-6714. Unless such demands are made, this permit shall be final
and binding.
If you need any additional information concerning this matter, please contact Ms. Shannon Mohr
Thornburg by telephone at [phone], extension 353, or via e-mail at
[e-mail].
Sinc r y,
for Gregory J. Thorpe, Ph.D.
cc: Ms. Caroline J. Edwards, L.S.S., Earthwise Designs
McDowell Health Department
Asheville Regional Office -Water Quality Section
Asheville Regional Office -Groundwater Section
Central Office -Groundwater Section .
Technical Assistance and Certification Unit
Non -Discharge Compliance/Enforcement Unit
Water Quality Central Files
NDPU Files
2

State of North Carolina
]Department of Environment
and Natural Resources
Asheville'Regional Office
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
Division of Water Quality
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
WATER QUALITY SECTION
November 5, 2002
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. J. Robert Boyette, City Manager
City of Marion
Post Office Box 700
Marion, North Carolina 28752
Subject: Attachment B Certification - Modification
Permit No. WQ0019960
City of Marion
Residuals Land Application Program
Land Application of Residual Solids (503)
McDowell County
Dear Mr. Boyette:
In accordance with your permit modification application package received on October 14,
2002; we are forwarding herewith a modified Attachment B, certified November 5, 2002, to the
City of Marion for the subject residuals land application program.
This certification is being issued to modify Attachment B with the addition of four (4) sites,
two (2) owners, with acreage in both McDowell and Burke counties, described below;
Property Owner Site Designation County Net Acreage
Ross, Wayne
R2
McDowell
12.0
Yang, Voua
Y1
McDowell
12.0
Queen, Frank
Q1
Burke
22.0
Queen, Frank
02
Burke
18.0
Asheville Regional Office, 59 Woodfin Place, Asheville, North Carolina 28801 Phone: [phone] Fax: [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled\110% Post Consumer Paper

Mr. Boyette
November 5, 2002
Page 2
Please replace the existing Attachment B of Permit No. WQ0019960 that was previously
certified on April 24, 2002, with this modified Attachment B certified on November 5, 2002. Note
that only the vicinity and buffer maps for the four (4) new land application sites are attached to
this modified Attachment B. It is the City of Marion's responsibility to ensure that a complete
permit is created, by inserting this modified Attachment B and vicinity and buffer maps into Permit
No. WQ0019960 issued on April 24, 2002, and making sure to retain the vicinity and buffer maps
for the three (3) existing and unmodified 'land application sites.
This modified Attachment B shall be effective from the date of certification, November 5,-
2002; shall void Attachment B of Permit No. WQ0019960 that was previously certified on April 24,
2002; and shall be subject to the conditions and limitations as specified therein, as well as those
specified in the above -referenced permit. As always, remember to take the time to review this
modified Attachment B thoroughly, as some of the conditions contained therein may have been
changed since the last certification. Note that this modified Attachment B is hereby incorporated
by reference into Permit No. WQ0019960 issued on July 7, 2002.
If any parts, requirements, and/or limitations contained in this certification or modified
Attachment B are unacceptable, you have the right to request an adjudicatory hearing upon
written request within 30 days following receipt of the certification. This request shall be in the
from of a written petition, conforming to Chapter 150B of the North Carolina General Statutes and
filed with the Office of Administrative Hearings at 6714 Mail Service Center, Raleigh, North
Carolina 27699-6714. Unless such demands are made, this permit shall be final and binding.
If you require any additional information concerning this matter, please contact Mr. Larry
Frost at [phone].
Sincerely,
xc: Caroline Edwards — Earthwise Designs
McDowell County Health Department
Larry Frost
Central Office -Groundwater Section
NDPU Files
NDPU Residuals Program Coordinator
GWS — ARO
Asheville Regional Office, 59 Woodfin Place, Asheville, North Carolina 28801 Phone: [phone] Fax: [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled\110% Post Consumer Paper

9
.. NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
LAND APPLICATION OF RESIDUAL SOLIDS (503) PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
City of Marion
McDowell County
FOR THE
continued optional operation of facilities for the lime stabilization of residuals generated by the residuals
source -generating facilities listed in the most recently -certified Attachment A and consisting of the
following minimum components: two 0.065-million gallon thickening units; two vacuum filters; a lime
storage silo; a pug mill that is provided with supplemental heat; a storage area; and all associated piping,
valves, electrical and instrumentation/control systems, and other appurtenances required to make complete
and functional facilities; and the
continued operation of a residuals land application program for the City of Marion and consisting the land
application of residuals generated by the residuals source -generating facilities listed in the most recently -
certified Attachment A to the land application sites listed in the most recently -certified Attachment B with
no discharge of wastes to surface waters, pursuant to a minor modification request from Mr. Larry Carver,
Wastewater Treatment Plant Supervisor for the City of Marion that was received on February 26, 2002,
and in conformity with the project plan, specifications, and other supporting data subsequently filed and
approved by the Department of Environment and Natural Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until June 30, 2006; shall void Permit No.
WQ0019960, issued on July 20, 2001; and shall be subject to the following specified conditions and
limitations:
I. PERFORMANCE STANDARDS
1. The residuals land application program shall be effectively maintained and operated as a non -
discharge system to prevent the discharge of any wastes resulting from the operation of this
program.

2. This permit shall become voidable if the soils of the land application sites fail to assimilate the
residuals adequately and may be rescinded unless the land application sites are maintained and
operated in a manner that will protect the assigned water quality standards of the surface
waters and groundwater.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface waters or groundwater resulting from the operation of this residuals land application
program.
4. In the event that the residuals land application program is not operated satisfactorily, including.
the creation of nuisance conditions, the Permittee shall cease land applying residuals to the
site, contact the Water Quality Section of the appropriate Division of Water Quality's
(Division) regional office, and take any immediate corrective actions as may be required by
the Division.
5. No residuals other than those generated by the residuals source -generating facilities listed in
the most recently -certified Attachment A of this permit shall be approved for land application
in accordance with this permit.
6. The pollutant concentrations in any residuals that are land applied to any land application site
shall not exceed the following Ceiling Concentrations (i.e., dry weight basis):
Parameter
Ceiling Concentration
(milligrams per kilogram)
Arsenic
75
Cadmium
85
Copper
4,300
Lead
840
Mercury
57
Molybdenum
75
Nickel
420
Selenium
100
Zinc
7,500
7. When residuals are land applied under the conditions of this permit, the Class A pathogen
requirements and site restrictions in 40 CFR Part 503.32(a) or the Class B pathogen
requirements and site restrictions in 40 CFR Part 503.32(b), and one of vector attraction
reduction requirements in 40 CFR Part 503.33 shall be met. Additionally, an evaluation shall
be performed that demonstrates the residuals' ability to comply with this requirement. Upon
request, a copy of this evaluation, including all test results and calculations, shall be submitted.
Only residuals that are generated by the residuals source -generating facilities that are
identified as being exempt from this condition in the most recently -certified Attachment A
shall not be required to comply with the specified pathogen reduction and vector attraction
reduction requirements.
8. Only the land application sites listed in the most recently -certified Attachment B of this permit
are approved for residuals land application.
2

9. This permit shall become voidable unless the agreements between the Permittee and the
landowners and lessees or operators of any land application sites listed in the most recently -
certified Attachment B of this permit not owned by the Permittee are in full force and effect.
These agreements shall be considered expired concurrent with the expiration date of the permit
and shall be renewed at the same time the permit is renewed.
10. The appropriate local governmental official (i.e., county manager, city manager, etc.) shall be
notified at least 24 hours prior to the initial residuals land application event to any new land
application site. In addition, the appropriate county manager's office shall be notified prior to
the initial residuals land application event on any new site so that they will be aware that
residuals land application activities have commenced on the site. -
11. The Water Quality Section of the appropriate Division's regional office shall be notified at
least 24 hours prior to the initial residuals land application event on any new land application
site. Such notification to the Regional Water Quality Supervisor shall be made during normal
office hours (i.e., from 8:00 a.m. until 5:00 p.m.) between Monday and Friday, but excluding
State Holidays. A list of the Division's regional offices, their county coverage, and their
contact information may be downloaded from the web site at http://h2o.enr.state.nc.us/ndpu/.
II. OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities and Iand application sites shall be properly maintained and operated at all times.
2. Upon classification of the residuals land application program by the Water Pollution Control
System Operators Certification Commission (WPCSOCC), the Permittee shall designate a
certified land application/residuals operator to be in responsible charge (ORC) of the program.
The operator shall hold a certificate of the type classification assigned to the program by the
WPCSOCC. The Permittee shall also designate a certified back-up operator of the appropriate
type to comply with the conditions of 15A NCAC 8G .0202.
3. No residuals shall be stored at any land application site at any time, unless written approval
. has first been requested and obtained from the Division.
4. A copy of this permit shall be maintained in all manned equipment at the land application sites
when residuals are being land applied during the life of this permit. A spill prevention and
control plan shall be maintained in all residuals transport and application vehicles.
5. When land applying residuals to any land application site, the following buffer zones shall be
maintained at all times:
a. 400 feet from residences or places of public assembly under separate ownership for
surface application methods; however, the buffer zone requirement may be reduced to a
minimum of 100 feet upon written consent of the owner and approval from the Water
Quality Section of the appropriate Division's regional office in Attachment B of this
permit;
b. 200 feet from residences or places of public assembly under separate ownership for
subsurface application methods; however, the buffer zone requirement may be reduced to
a minimum of 100 feet upon written consent of the owner and approval from the Water
Quality Section of the appropriate Division's regional office in Attachment B of this
permit;
3

c. 100 feet from any public or private water supply source, waters classified as SA or SB,
and any Class I or Class II impounded reservoir used as a source of drinking water for
both methods;
d. 100 feet from any streams classified as WS or B, any other stream, canal, marsh or coastal
waters and any other lake or impoundment for surface application;
e. 50 feet from any streams classified as WS or B, any other stream, canal, marsh or coastal
waters and any other lake or impoundment for subsurface application;
f. 50 feet from property lines for both surface and subsurface application methods;
g. 50 feet from public right of ways for both surface and subsurface application methods;
h. 10 feet from upslope interceptor drains and surface water diversions for both surface and
subsurface application methods; and
i. 25 feet from downslope interceptor drains, surface water diversions, groundwater drainage
systems, and surface drainage ditches for both surface and subsurface application methods.
Some of the buffers specified above may not have been included in previous permits for this
residuals land application program. However, any land application sites that are listed in the
most recently -certified Attachment B of this permit, but were approved with different buffers
shall be reflagged to comply with these buffers.
6. Maximum slope for land application of residuals shall be 10 percent for surface application
methods and 18 percent for subsurface application methods.
Specific residuals land application area boundaries shall be clearly marked on each land
application site prior to and during a residuals land application event.
8. The metal loading rates on. any land application site shall not exceed the following
Cumulative Pollutant Loading Rates (CPLRs):
;;Parameter
CPLR
(kilo rams er hectare)
CPLR
founds per acre)
Arsenic
41
36
Cadmium
39
34
Co er
1,500
1,338.
Lead
300
267
Merc
17
15
Molybdenum
n/a
n/a
Nickel
420
374
Selenium
100
89
Zinc
2,800
2,498
9. An acceptable pH shall be maintained in the soil, residuals, and lime mixture, greater than 6.0,
on all land application sites onto which residuals are land applied to ensure optimum yield for
the crops specified in Condition II. 13. The agronomist shall provide information on the pH
best suited for the specified crop and the soil type.
4

y._
10. Should any of the residuals generated by the residuals source -generating facilities listed in the
most recently -certified Attachment A of this permit contain a high salt content (i.e., high
sodium adsorption ratio (SAR) of five or higher), the exchangeable sodium percentage (ESP)
or other method as approved by the Division, using the results from the annual soils analysis
as required by this permit, shall be monitored on all of the land application sites. The local
Cooperative Extension Office, the Department of Agriculture and Consumer Services, the
Natural Resource Conservation Service, a North Carolina -licensed Soil Scientist, or other
agronomist shall review the results and make recommendations regarding soil amendments
(e.g., gypsum, etc.) or other ameliorative mechanism for maintaining the integrity of the site in
terms of suitability for land application of residuals and maintaining conditions conducive to
crop growth. The Permittee shall implement such recommendations accordingly and shall
maintain written records of each monitoring event that includes details of the sites covered and
rate of soil amendment application.
11. Prior to land applying residuals to any land application site that has previously received or is
intended to receive animal waste (e.g., poultry litter, etc.) or other source of nutrients (e.g.,
fertilizer, etc.) in -the future, the Permittee shall obtain information pertaining to the volume
and analysis of the applied waste/nutrients from the landowner and/or lessee/operator of the
site. The Permittee shall be responsible for verifying the volume of residuals that may be land
applied to the site such that the plant available nitrogen (PAN) loading rate for the specified
crop (i.e., see Condition II. 13.) shall not be exceeded by all of the sources of PAN applied.
Should the maximum PANT loading rate be met or exceeded, then no additional residuals shall
be land applied to the site.
12. A suitable vegetative cover, as listed in Condition H. 13., shall be maintained on land
application sites onto which residuals are land applied in accordance with the crop
management plan outlined by the local Cooperative Extension Office, the Department of
Agriculture and Consumer Services, the Natural Resource Conservation Service, or other
agronomist and as approved by the Division.
5

13. Residuals and other sources of PAN shall be land applied to all land application sites at
agronomic rates in accordance with the crop management plan outlined by the local
Cooperative Extension Office, the North Carolina Department of Agriculture and Consumer
Services, the Natural Resource Conservation Service, or other agronomist. Under no
circumstances shall the following PAN loading rates land applied to any site exceed the
following for the specified crops:
PAN
PAN
Crop
(pounds per
Crop
(pounds per
acre per ear)
acre per year)
Alfalfa
200
Forest
75
(Hardwood or Softwood)
Bermuda Grass
(Ha or Pasture)
220
Milo
100
Blue Grass
120
Small Grain
100
(Wheat, Barley, or Oats)
Corn
160
Sorghum or Sudex
(Grain)
(Pasture)
180
Corn
200
Sorghum or Sudex
220
(Silage)
(Silage)
Cotton
70
Soybeans
200
Fescue
250
Timothy, Orchard, or
200
Rye Grasses
The Permittee shall apply for and receive a modification of this permit before land applying
residuals on any land application site that is to be established in a crop other than those listed
above. A maximum PAN loading rate for the desired crop shall be approved with the permit
modification.
If the land application sites are to be overseeded (e.g., bermuda grass in the summer and rye
grass in the winter with BOTH crops to receive residuals), then the second crop shall receive
an application of PAN at a rate of no greater than 50 pounds per acre per year. This practice
shall be allowed as long as the second crop is to be harvested. If the second crop is to be
planted for erosion control only and is to be tilled into the soil, then no residuals shall be land
applied to these sites because the PAN will essentially be returned to the soil.
Residuals shall not be land applied at rates greater than agronomic rates, unless authorized by
the Division.
14. Animals shall not be grazed on any land application site for 30 days after any residuals land
application event. Sites that are to be used for grazing shall have fencing that will be used to
prevent access after each event.
15. Food crops, feed crops, and fiber crops that do not come in contact with the residuals shall not
be harvested for 30 days after any residuals land application event.
16. Food crops with harvested parts that touch the residual/soil mixture and are totally above the
land surface (e.g., tobacco, melons, cucumbers, squash, etc.) shall not be harvested for 14
months after any residuals land'application event.
G

17. Food crops with harvested parts below the surface of the land (i.e., root crops such as potatoes,
carrots, radishes, etc.) shall not be harvested for 20 months after any residuals land application
event when the residuals remain on the land surface for four months or longer prior to
incorporation into the soil.
18. Food crops with harvested parts below the surface of the land shall not be harvested for 38
months after any residuals land application event when the residuals remain on the land
surface for less than four months prior to incorporation into the soil.
19. Turf shall not be harvested for one year after any residuals land application event.
20.. Adequate provisions shall betaken to prevent wind erosion and surface runoff from conveying
residuals from the land application sites onto adjacent properties or into any surface waters.
21. Adequate procedures shall be provided to prevent surface runoff from carrying any land
applied or stored residuals into any surface waters.
22. Surface -applied residuals shall be plowed or disced within 24 hours after land application on
land application sites with no cover crop established.
23. For land application sites that are prone to flooding or within the 100-year flood elevation,
residuals shall be land applied only during periods of dry weather. The residuals shall be
incorporated into the soil within 24 hours after land application.
24. Residuals shall not be land applied during inclement weather or until 24 hours following a
rainfall event of 0.5-inch or greater in 24 hours. Any emergency residuals land application
measures shall first be approved in writing by the Division.
25. Residuals shall not be land applied to any land application site that is flooded, frozen, or
snow-covered.
26. Appropriate measures shall be taken to control public access to the land application sites
during active site use and for the 12-month period following the last residuals land application
event. Such controls may include the posting of signs indicating the activities being
conducted at each site.
III. MONITORING AND REPORTING REOUIREMENTS
1. Any monitoring (i.e., including groundwater, surface water, residuals, soil, or plant tissue
analyses) deemed necessary by the Division to ensure protection of the environment shall be
established, and an acceptable sampling and reporting schedule shall be followed.
7

2. Residuals generated by each residuals source -generating facility listed in the most -recently -
certified Attachment A of this permit shall be analyzed to demonstrate that they are non-
hazardous under the Resource Conservation and Recovery Act (RCRA). A corrosivity,
ignitability, and reactivity analysis as well as a Toxicity Characteristics Leaching Procedure
(TCLP) analysis shall be conducted on residuals generated by each residuals source -
generating facility listed in the most recently -certified Attachment A of this -permit. The
analyses shall be performed at the frequency specified in the most recently -certified
Attachment A of this permit, and the results shall be maintained on file by the Permittee for a
minimum of five years. If residuals generated by a particular residuals source -generating
facility are land applied at a frequency less than that which is specified in the most recently -
certified Attachment A of this permit, the analyses shall be required for each residuals land
application event. Only residuals that are generated by the residuals source -generating
facilities that are identified as being exempt from this condition in the most recently -certified
Attachment A of this permit shall not be required to comply with this monitoring requirement.
The TCLP analysis shall include the following parameters (i.e., note the regulatory level in
milligrams per liter in parentheses):
Arsenic (5.0)
1,4-Dichlorobenzene (7.5)
Nitrobenzene (2.0)
Barium (100.0)
1,2-Dichloroethane (0.5)
Pentachlorophenol (100.0)
Benzene (0.5)
1,1-Dichloroethylene (0.7)
Pyridine (5.0)
Cadmium (1.0)
2,4-Dinitrotoluene (0.13)
Selenium (1.0)
Carbon tetrachloride (0.5)
Endrin (0.02)
Silver (5.0)
Chlordane (0.03)
Hexachlorobenzene (0.13)
Tetrachloroethylene (0.7)
Chlorobenzene (100.0)
Heptachlor (and its hydroxide) (0.008)
Toxaphene (0.5)
Chloroform (6.0)
Hexachloro-1,3-butadiene (0.5)
Trichloroethylene (0.5)
Chromium (5.0)
Hexachloroethane (3.0)
2,4,5-Trichlorophenol (400.0)
m-Cresol (200.0)
Lead (5.0)
2,4,6-Trichlorophenol (2.0)
o-Cresol (200.0)
Lindane (0.4)
2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0)
Mercury (0.2)
Vinyl chloride (0.2)
Cresol (200.0)
Methoxychlor (10.0)
2,4-D (10.0)
Methyl ethyl ketone (200.0)
After the residuals have been monitored as specified above for two years at the frequency
specified in the most recently -certified Attachment A of this permit, the Permittee may submit
a request to the Division for a permit modification to request
a reduction of this monitoring
requirement. In no case, however, shall the frequency of monitoring be less than once per
permit cycle.

3. An analysis shall be conducted on residuals generated by each residuals source -generating
facility listed in the most recently -certified Attachment A of this permit. The -analysis shall be
performed at the frequency specified in the most recently -certified Attachment A of this
permit, and the results shall be maintained on file by the Permittee for a minimum of five
years. If residuals generated by a particular residuals source -generating facility are land
applied at a frequency less than that which is specified in the most recently -certified
Attachment A of this permit, an analysis shall be required for each residuals land application
event. The analysis shall include, but shall not necessarily be limited to, the following
parameters:
Aluminum
Ammonia -Nitrogen
Arsenic
Cadmium
Calcium
Copper
Lead
Magnesium
Mercury
Molybdenum
Nickel
Nitrate -Nitrite Nitrogen
Percent Total Solids
pH
Phosphorus
Potassium
Selenium
Sodium
Total Kjeldahl Nitrogen
Zinc
Plant Available Nitrogen
(by calculation)
After the residuals generated by a particular residuals source -generating facility have been
monitored for two years at the frequency specified in the most recently -certified Attachment A
of this permit, the Permittee may submit a request to the Division for a permit modification to
reduce the frequency of this monitoring requirement. In no case, however, shall the frequency
of this monitoring be less than once per year when a residuals land application event of
residuals generated by the residuals source -generating facility occurs during that year.
4. Residuals generated by each residuals source -generating facility listed in the most recently -
certified Attachment A of this permit shall be monitored for compliance with Condition I. 7.
The monitoring shall be performed at the frequency specified in the most recently -certified
Attachment A of this permit, and data to verify pathogen and vector attraction reduction of the
residuals shall be maintained on file by the Permittee for a minimum of five years. The
_.� required data shall be specific to the stabilization process utilized, but also shall be sufficient
to demonstrate clear compliance with the Class A pathogen reduction requirements in 40 CFR
Part 50332(a) or the Class B pathogen reduction requirements and site restrictions in 40 CFR
Part 503.32(b) as well as one of vector attraction reduction requirements in 40 CFR Part
503.33. In addition, the Environmental Protection Agency (EPA) certification statements
concerning compliance with pathogen reduction requirements, vector attraction reduction
requirements, and management practices shall be completed quarterly by the proper authority
or authorities, if more than one is involved (i.e., either the person who prepares the residuals,
the person who derives the material, or the person who applies the residuals). Only residuals
that are generated by the residuals source -generating facilities that are identified as being
exempt from Condition I. 7. in the most recently -certified Attachment A of this permit shall
not be required to comply with this monitoring requirement.
5. Laboratory analyses as required by Condition III. 2., Condition III. 3., and Condition III. 4.
shall be performed/gathered on the residuals as they are to be land applied. Furthermore,
analytical determinations made pursuant to the monitoring and reporting requirements of this
permit shall be made by a laboratory certified by the Division for the required parameter(s)
under 15A NCAC 2H .0800 or 15A NCAC 2H .1 i00.
6

6. Proper records shall be maintained by the Permittee tracking all residuals land application \`
events. These records shall include, but are not necessarily limited to, the following
information:
a. Source of residuals;
b. Date of land application;
c. Location of land application (i.e., site, field, or zone number);
d. Method of land application;
e. Weather conditions (i.e., sunny, cloudy, raining, etc.);
f. Soil conditions (i.e., dry, wet, frozen, etc.);
g. Type of crop or crops to be grown on field;
h. Volume of residuals land applied in gallons per acre, dry tons per acre, or kilograms per
hectare;
i. Volume of animal waste or other nutrient source applied in gallons per acre, dry ton per
acre, or kilograms per hectare (if applicable);
j. Volume of soil amendments (i.e., lime, gypsum, etc.) applied in gallons per acre, dry ton
per acre, or kilograms per hectare (if applicable); and
i. Annual and cumulative totals of dry tons per acre of residuals as well as animal waste and
other source of nutrients residuals (i.e., if applicable), annual and cumulative pounds per
acre of each heavy metal (i.e., shall include, but shall not be limited to, arsenic, copper,
lead, mercury, molybdenum, nickel, selenium, and zinc), annual pounds per acre of PAN,
and annual pounds per acre of phosphorus applied to each field.
7. A representative annual soils analysis (i.e., Standard Soil Fertility Analysis) shall be
conducted on each land application site on which a residuals land application event in the
respective calendar year has occurred or is to occur, and the results shall be maintained on file
by the Permittee for a minimum of five years. The Standard Soil Fertility Analysis shall
include, but is not necessarily limited to, the following parameters:
Acidity Exchangeable Sodium Percentage (by calculation)
Calcium Magnesium Phosphorus
Cation Exchange Capacity Manganese Potassium
Copper Percent Humic Matter Sodium
Base Saturation (by calculation) pH Zinc
8. Three copies of all required monitoring and reporting requirements as specified in Condition
III. 1., Condition III. 2., Condition 111. 3., Condition III. 4., Condition III, 5., Condition III, 6.,
and Condition III. 7. shall be submitted annually on or before March 1st of the year following
the residuals land application event to the following address:
. NCDENR-DWQ
Water Quality Section
Non -Discharge Compliance/Bnforcement Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
10

Noncompliance Notification:
The Permittee shall report by telephone to the Water Quality Section of the Division's
Asheville Regional Office at telephone number [phone], as soon as possible, but in no
case more than 24 hours or on the next working day following the occurrence or first
knowledge of the occurrence of any of the following:
a. Any occurrence with the residuals land application program that results in the land
application of significant amounts of residuals that are abnormal in quantity or
characteristic.
b. Any failure of the residuals land application program resulting in a release of material to
receiving waters.
c. Any time that self -monitoring information indicates that the residuals land application
program has gone out of compliance with the conditions and limitations of this permit or
the parameters on which the program system was designed.
d. Any process unit failure, due to known or unknown reasons, that render the residuals land
application program incapable of adequate residuals treatment.
e. Any spillage or discharge from a vehicle or piping system transporting residuals to the
application site.
Persons reporting such occurrences by telephone shall also file a written report in letter form
within five days following first knowledge of the occurrence. This report shall outline the
actions taken or proposed to be taken to ensure that the problem does not recur.
IV. GROUNDWATER REQUIREMENTS
1. Land Application Site Requirements:
a. Each land application site identified with a GW-A 'in the most recently -certified
Attachment B of this permit is dominated by soils with a mean seasonal high water table
greater than three feet below the land surface. Residuals land application events may
occur on these sites throughout the year.
b. Each land application site identified with a GW-B in the most recently -certified
Attachment B of this permit is dominated by soils with a mean seasonal high water table
between one and three feet below the land surface. Residual land application events on
these sites shall be prohibited from December through March, inclusive. No residuals
shall be land applied to these sites when the vertical separation between the depth. of
residuals land application and the water table is less than three feet. The actual water
table depth for seasonally -restricted soils shall be verified by soil borings within 24 hours
prior to any residuals land application event that occurs from April through November,
inclusive. The number of borings advanced shall be sufficient to characterize water table
conditions across the land application site adequately. Any open borings shall be properly
filled with native soil, prior to the residuals land application event, to decrease the chance
of any residuals contaminating the groundwater.
11

2. Applicable Boundary Requirements:
a. The COMPLIANCE BOUNDARY for residuals land application programs is specified by
regulations in 15A NCAC 2L (i.e., "Groundwater Classifications and Standards"). The
Compliance Boundary for each land application site is established at either 250 feet from
the residuals land application area or 50 feet within the property boundary, whichever is
closest to the residuals land application area. An exceedance of Groundwater Quality
Standards at or beyond the Compliance Boundary is subject to immediate remediation
action according to 15A NCAC 2L .0106 (d)(2).
b. The REVIEW BOUNDARY shall be established around each land application site
midway between the Compliance Boundary and the perimeter of the residuals land
application area. Any exceedance of Groundwater Quality Standards at the Review
Boundary shall require action in accordance with 15A NCAC 2L .0106 (d)(2).
3. Additional Requirements:
a. Any groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
V. INSPECTIONS
1. Prior to each residuals land application event, the Permittee or his designee shall inspect the
residuals storage, transport, and application facilities to prevent malfunctions and
deterioration, operator errors, and discharges that may cause or lead to the release of wastes to
the environment, a threat to human health, or a nuisance. The Permittee shall. maintain an
inspection log or summary including at least the date and time of inspection, observations
made, and any maintenance, repairs, or corrective actions taken by the Permittee. This log of
inspections shall be maintained by the Permittee for a period of five years from the date of the
inspection and shall be made available to the Division or other permitting authority, upon
request.
2. Any duly authorized officer, employee, or representative of the Division may, upon
presentation of credentials, enter and inspect any property, premises, or place on or related to
the land application sites or facilities at any reasonable time for the purpose of determining
compliance with this permit; may inspect or copy any records that must be' kept under the
terms and conditions of this permit; and may obtain samples of groundwater, surface water, or
leachate.
VI. GENERAL CONDITIONS
This permit shall become voidable unless the residuals land application events are carried out
in accordance with the conditions of this permit, the supporting materials, and in the manner
approved by the Division.
2. This permit shall be effective only with respect to the nature and volume of residuals described
in the application and other supporting data.
3. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division in accordance with North Carolina General
Statutes § 143-215.6A through § 143-215.6C.
12

4. The annual administering and compliance fee shall be paid by the Permittee within 30 days
after being billed by the Division. Failure to pay the fee accordingly may cause the Division
to initiate action to revoke this permit, as specified by 15 NCAC 2H .0205 (c)(4).
5. The issuance of this permit does not preclude the Permittee from complying with any and all
statutes, rules, regulations, or ordinances that may be imposed by other government agencies
(i.e., local, state, and federal) which have jurisdiction, including, but not limited to, applicable
river buffer rules in 15A NCAC 2B .0200, soil erosion and sedimentation control requirements
in 15A NCAC Chapter 4 and under the Division's General Permit NCGO10000, and any
requirements pertaining to wetlands under 15A NCAC 2B .0200 and 15A NCAC .0500.
6. This permit may be modified, revoked, and/or reissued to incorporate any conditions,
limitations and monitoring requirements the Division deems necessary in order to protect the
environment and public health adequately.
7. The Permittee, at least six months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Division shall review the adequacy of the facilities
and residuals land application program described therein, and if warranted, shall extend the
permit for such period of time and under such conditions and limitations as it may deem
appropriate.
8. This permit shall not be automatically transferable. In the event that there is a desire for the
residuals land application program to change ownership or to change the name of the
Permittee, a formal permit request shall be submitted to the Division documentation from the
parties involved and other supporting materials as may be appropriate. The approval of this
request shall be considered on its merits and may or may not be approved.
Permit issued this th;,twenty-fourth day of April, 2002.
NORTH LINA E NMENTAL MANAGEMENT COMMISSION
Lor Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0019960
13

ATTACHMENT A Annrnved Residual S me eneraline facilities
Pe—ft No. WQ0019960
City of Marion
City of Marion Residuals Land Application Program
Owner Fucllily Name ICounty
Total
Permit Number
Issued BY
is 5037
Mnxlmum
Dry'rons
Per Year
Monitoring
Frequency for
Condition 111. 2.
Monitoring
Frequency for
Condition 111. 3. and
Condition III.4.
Approved
Mineralization
Rate
NC0031879
DW
503
290.00
Annual)
Annual)
0.30
290.00
Permit No. WV 760 Pagr
Certification Date: t, 2002
i

ATTACHMENT B - Approved Land Application Sites
Permit No. IVQ0019960
City of Marion
City of Marion Residuals Land Application Pr•ogranr
Site/Field ID
Landowner
Lessee/Operator
County
Latitude
Longitude
Net Acreage
Applicable
Restriction in
Condition IV. 1.
C 1 a
McDowell
9.50
GW-A
Klb
Khan , Toua & Tong
McDowell
16.00
GW-A
K2`'d
Khang, Toua & Tong
McDowell
38.00
GW-A
R1
Ross, Wayne
McDowell
16.00
GW-A
R2
Ross, Wayne
McDowell
12.00
GW-A
Y1
Yang, Voua
McDowell
12.00
GW-A
Q1
Queen, Frank
Burke
22.00
GW-A
Q2
Queen, Frank
Burke
18.00
GW-A
Total For County
McDowell
103.50
Total For County
Burke
40.00
Total.
143.50
a A reduced buffer from a residence under separate ownership has been approved for this land application site. Residuals may be land applied to within 100 feet of the residence
owned by John Kirby (i.e., indicated by the label "D1" on the approved buffer map), regardless of whether a surface or a subsurface application method is used.
b Reduced buffers from residences under separate ownership has been approved for this land application site. Residuals may be land applied to within 100 feet of the residences
owned by Ruby Kelley (i.e., indicated by the labels "DI" and "D2" on the approved buffer map) and to within 200 feet of the residences owned by Sy Thau (i.e., indicated by the
labels "133" and "04" on the approved buffer maps), regardless of whether a surface or a subsurface application method is used.
This land application site was previously an apple orchard that has since been converted to pasture land. The Division's Groundwater Section has expressed concern regarding
the historical pesticide application practices at the site and the fact that these could have adversely impact soil and groundwater quality. Although it is not a requirement
of this permit, it is strongly advised that the Permittee receive a "hold harmless" agreement with respect to prior contamination before land applying residuals to this site.
d Reduced buffers from residences under separate ownership has been approved for this land application site. Residuals may be land applied to within 200 feet of the residences
owned by Chia Kee Yang (i.e., indicated by the labels "D5" and "D6" on the approved buffer map) and to within 200 feet of the residence owned by Kenneth D. VanBuskirk
(i.e., indicated by the label "D7" on the approved buffer maps), regardless of whether a surface or a subsurface application method is used.
• ~ Pen -nit No. WQ0019960 Page 1 of I Certification Date: November 5, 2002

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Jan 04 05 (18:40a Branch Redduals 3365100341 p.2
State of North Carolina
Department of E»vi ronment .a)3d Natural Resources
Ditvisiou of Water Quality
WATERSHED CLASSIUCATION ATI-ACHMENT
FOR RESIDUALS PROGRAMS
{'r ISM'C.Rt iVAYQEFH0TOCOPM0FOR U5EAS,4A'0MCrVA7Q
The Diiviision a Water Quality {Division) wiU not cong$der this attachment form to be cowplete
unless all the instructions axe followed. Failure to follow the instmetions or to submit AR of the
required items will lead to additipAal processing aAd review time.
For more information or.for at; electronic verslan of it' is form, visit out' web site at: iwp:ffii2o.cmr state nc wladpm,'
INSTRUCTIONS TO THE APPUCANT.-
Atr. Attachment Fornu
✓ Do not submit this attachment form for review without x corresponding reslduals program
application form (Form NDRLA,,IP).
Any changes to this atlsclun=t form will result in rlke applieadon pankage being tetucncd.
B. Prepare the attachment form with the reque-Aed information for each location where the residuals
programs activities are planned to occur within a particuLar regional office county coverage.
✓ Additional topics of Page 2 of 2 of this attachment form may ba umd if aecess ary.
Use a portion of asp 8.$-inch by 11-iDzh copy of the portion of a 7.5-minute USGS Topographic Map to
identify the location where tho rexidmIs program activities are plaiwerd to occur as well as the closest
downslope surface waters as clearly its possible_ Eaoli map portion must be labeled with the .upp mime and
number, the identified location, and be of clear and reproducible Quality
� Latitndw and longitudes must reported as being based on either the NAD 27 or the \TAD 93 data systems.
f Acceptable methods of determining location latitudes and longitude and their corresponding codes are as
follows;
Addzest Matching (ADD) + Digits] or Raw Photo Extraction (EXT)
i Aetial photography with Cround Control (AER) i Geodetic Quality GPS Survey (GEO)
♦ CadasstrA Survey (SUR) t LORAN-C Navigation Device (I.OR)
+ Conversion from Caardimle Plane (CP) # Navigation Quality GPS (CPS)
Conversion. from Township -Section -lie (TSR) ♦ Remote sensing (RS)
Conversion from Universal Ttabs Mere (U11I) * Zip Code Centroid (ZIP)
+ Map Interpretation by Digital or Mamial 1xtraction (MAP)
✓ Location accuracy must be provided to the neat unit (c.g., nearest second, tenth of a second, etc.).
C. Mail or fax the attachment form and the map porrdons to the appropriate regional mite .for —AevF and
to obtain the waterbody and elass3fication information.
.r A list of the Division's regional offices, their wonty coverage;, and their contact information may be
downloaded from the web site at hug:/th2a.enr.state.nv.u�fndpni.
+r The Division will not comsider this attachme rt form to be compfc-tc until it is oompleted by the appropriate
regional office_
To: Regional office: NCDENR DWQ AsbovilL- Rcgioual OtTico
Addrase of regional office: 2096 Ufi l llghway 70
City: Swaim moo _ st itc: - NC Zip: 28778 _
Facsimile numb= ( 828 ) 294 7043
Please provide cue with the waterbody nume(s), streaam index number(s), and vo rrent/proposed
elassifirAtion(s) of the surface waters that are closest to and dov wslope from the lom ions) where the
proposed residuals program activities Ire planned to occur, as identified on the attached map segment.
signature of regional office staff: - / ./ CeG _v hate. I IJ- a6-
.FORM: RNSCA O2ft)2 Page 1 ol? Attacbm t Order 3-a
E,
JAN 4 2005
COJ<<li�/i{7Ffi SCCfI�i�
1---lSHEV!LlF Rr GI�I�Ai` urhlCE

Location
1D
County
LattRude
Longitude
Location
Datunt
Location
Method
Code
Location
Accuracy
Waterbody► Subbasla and
StrexmIudexWo,
(t"o
(TO BeXe Cornpleted:By n�l��
Current Bud
PreposcdClass
BeCompleted By
_
F-1
Mc17oweU
35° 35' 39.08" N
81° 31' 03.34''
NAD 27
'him
f 1'�
ca$ W-212 -9-2
F-2
McDowe l
35° 35' 31,62" N
8 1 * 5 1"00-35"N
NAD 27
MAP
f 1 "
ram 10 Co3-09-36)
F-3
McDowell
35133' 32.$6" N
81' 50' 42.17" 11
NAD 27
NI}1.P
f 1 "
cTS 20 CO3-0$m.�
G
F-4
McDDwz:11
35° 35' 30.99" N
81° 50' 36.41" NJ
NAD 27
NW
Q10
l&DDwcll
55" 4(Y 29.69" N
919 51' 32.35" N
NAD 27
MAP
1 "
CTS oC©3-08-30
G
Q13A
McDowell
359 39' 55.66" N
911 5l' A44" N
NAD 27
MAP
f 1 "
C j $ .30 ©� ©5-0 T .
C
Q13B
McDowell
35° 39' 54.79" N
81" 5l' 41.15" X
.NAD 27
NIAP
1 "
G7830 603-06-3-0)
C-
Q 15
McDawell
35039' 52.30" N
910 51' 24,77"
NAD 27
MAP
t 1 "
c i8 3 �C®3®fig-30
C
Q16
McDowell
35" 39' 24.97"i+f
NA13 27
AiAP
t 1 +
eTS 30 (a3}-08-3®C
Q20
McDowell
35139' 08.33" N
81 ° 51+ 22.95" 1
NAD 27
MAP
t 1 '•
C 7"$ 3o (5.3.08- 30
Q21
McDowell
35° 39' 08,58" N
$1° SI' 13.85" 1
NAD 27
NMP
+C
Q23
M. cDowell
35" 38' 44.35" N
911 51' 16AII V
NAD 21
hW
1 1 "
C;ro (a3-0 T'30)
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C. DEPARTMENT OF ENVIRONP IT AND
l,�j�, NATURAL RESOURCES
,` �DIVISION OF WATER QUALITY
NCDEQ`"� .fir^DE ry1�T PROTECTION S-ee4i'on
NRO' ASHEVILLE REGIONAL OFFICE
2090 U.S. HIGHWAY 70
SWANNANOA, NORTH CAROLINA 28778
PHONE:[phone] FAX:[phone]
W.
FAX: 33�- �1p'03sF1
FROM: �e
TE:
# OF PAGES INCLUDING COVER:
S o, is
MESSAGE: If questions, please call 828/296-4500
V
NonrthCarolina

Jan 134 05 09:40a Branch Radduals
3365100341 p.1
0
Branch Resides lc +c L Sons, I.LG
� a
.'
:I
312 B 'S®nt]t Wes * Drlvr - Qreemsboc«rt NC 27407
PHONE (336)$10-81. 48 FAX (3 36) SM0341CD
f 1
3
T'7
T0: Bcv Price From: Bob Branch
F'vY: (82$) 299-7043 Pages; c7
Pfm m Des, 1=7.' 111VIOS
RM. 'Watcnhed Chvjifec�oa cc.
0 ulymt © For Review Q Max Comment U plrasc RgIIX 0 Picric k2ocpcic
Bev,
Pleaw find the attached water hed &-wif cation famres for Marion and 3pz ace Fine. Ply
comrplctte these Ib=s and return d= to me. 7banks for your help. Call me at (336) 510-
0340 if you gave any questions.
LI.M.

I acatiatt
1D
County
Lattitude
Longitude
Location
Datat
Location
Method
Code
Loeatian
Accuracy
Waterbody Subbasin and
Stream Index ND.
(2'c� Be Carnplered B7' Dlf'�j
Current Bud
Proposed Glass
(To Be Completed By
DF1'�T}
F-1
NicDowel]
35" 35' 39kS" N
81051' 03.54"
NAD 27
MAP
F-2
McDowell
3503s' 31.62" N
81° 51' 00.33"
NAD 27
MAP
F-3
McDoweLl
35133' 32.86" N
81' 50' 42.tT"' 1
NAD 27
1W
f 1 "
F-4
McDowell
35135' 30.99" N
S 1° 54' 36.41" 1
NAD 27
NL?LF
1Q10
WDDwOl
350 40' 29.0" N
81 ° 51' 32.35" t
I AD 27
MAP
tQ13A
McDow•all
351139' 55.66" N
81° 51" 58.44" 1
NAD 27
MAP
Q 13 B
c-Nwell
35" 39' S4.79" N
8 I° 51' 41.15" 1
NAD 27
MAP
� 1
Q 15
MaDaw'ell
350 39' S2.30" 1`:
81 ° 51' 24.77" 1
NAD 27
MAP
Q16
NicDowel
35' 39' 24.97"N
81° 51' 23.25" t
NAD 27
MAP
Q20
McDowell
3511 39' 08.33" N
81 ° 51' 22.9311 V
NAD 27
MAP
Q21
NkDowed
35° 39' 08.55" N
81151' 13.85" N,
NAD 27
NMP
I it
Q23
McW wdl
35° 38' 44.33" N
91' 5F 16.93" 11
NAD 27
NW
FF
"'" LIND OFFOP01 RWSCA 02102 —*
-B
w
FMnL RWSCA 02fO2 Page 2 of 2 Attachment Order 3-a

Jan 134 05 09:40a
Branch Regduals
3305100341 p.4
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USGS DysartsWlhe, North Carolina 7.5 Minute Topagmphie QKadraxig*
sul. AW: 1•' 2Q04' City of Marion 11SGS
chica snr: Lan,d Application Program 'l'opa
uxrttvrrw: ftTS B71t.'NCB[ John Fisher F�unlat KU
SIIXJALS P
Drf'1'!I OW,4D4 {h,SOMSr LJA-- eYq—F& zoaynt

Jan 134 05 00:41a —Branch Redduals 33M5100341 p.8
USC, S Spruce Niue and Little Switzer land, Narth Carolina 7S MinutC T4poeraphir Qua&au-ies
Town oi' Sprute Fine
vutuv[`opo
" kAWN OY' PRTB Tommy Phillips Farm Map
un'rer
er_ Land Application Progmm Uoo-4i *aEsX.Y.0 P^laiYaI 2W4-37

vS4 ir' ir=r itiyN
Mati�f 1 L1.W 1 �. j
y1 )'�" � Jim '••.-._fr
311 S SOU& Westgale liriae - y`reenxiboro NC 274
PHONE (33G)S1A-0340-Ft1 (336)51[1.034.1 �?if
�G 7 Co �
i �
- — - C,� fs
To: Bcv i'tica From
F:MC {fi2fi) Z94-7043
Pagcs:
MOM Data 12/27/2004
RE, Watec�ed Oasstkation
❑ U:At Q FvrRcvImv ❑ PlcascC,Mrnnau ❑ PIg0 P-Pry ❑ Rcwe RGcyda
Bev,
Please find the attached. WawAcd cl;assifiCaUon forms fur Marian and Spruce pine. )
mplc�te a forms. and- return khan to me.na6l' for )r= haIP. Call me at (336) 510-
0340 ifyou have ally qucstions.
:..

n
U
0
Dsc 27 04 12:28p Branch Radduals
State of North Carolina
3365100341 p.2
Department of Environment and Natural Resources
Division of Water Quali4r
WATERSHED CLASSIFICATION A'I TACEMWNT
FOR RESIDUALS pRo GRAMS
(7717sFORmIV YBE P.romct7,PfEDF0e ww isAvo?j rLvAp
The Division of Water Quality {DivisiM,n) vt,j'L] tot co" cier this attach ent form to be complete
unless all the instmetiions are follower. Failure to follow tb,e instroAcdons or to submit all of the
Ynq(tr:ro.� :f-..,wa �..:rl w.....� .,.. .aKi:..='----• r - . _--� =--- .........
�++.. .+,...,.: �..z_ :; 1.,,. -,!w .�.. ...�.... ..,aic: �...nnt .J-arJrrfC?lri; 'I'.{4•�L [fAT ::1A �: 1--i M•-A.Y.r .vHStii - .
j.[!T_RTi(f'f["'I�flti�f/v'�.�-�•u iy ln�l_�rr+`?CT_ _._ .. _.__ ._ ..
+&•tfaGbOL=Li r• VA MA:
. _... _ _.. _.-__•._ _.. •• e..r^:2PVi.tia4l2:.-...Ye1�_:: ae: ::_e::vee
itp4r'++c:.iica•=ax+c :�. La.0 T�2)12\:icY�." - - - --
'r -Any �b rt ={,- r,...Ya4iusr2.asacmwnm-wiirlrFiSti aj'PixiuuUxA paoi3g0 0ciff-ee t'k turuica.
_- _ _ _ _ ___ �....-..�... .�..... .. r „ �.i�-s.:� aazarma..+ft. rv. cna.AA itBCaU{Ijj {t�it•1`. xit� i'C&aflal9lx
-,;K.,,ruz vinuce courk-4 wreratge.
•/ Additional copies of`Page 2 of 2 of this attadiment fcuxn mdy%e Imed ifzteces'saty.
✓ Uce it portiQ4 of an 8_5-mach by 1 l-inch coQy of the portion of a 7-5-minute USGS Topoyrapbfc Map to
identify the, 1t1C 60n wharr. tlx� ma;rh�aia Jrrntv,.r. ce•-- _:_. .'------.'
{}4i}RfjlllyT4.`.,y..: �J� .._vJ MGlf.:ili �C-_:f:Z�R.•.'1!.' �1S•xT lr. _.L:,...4 _ -YZ _
-it.'_7.1.T8_ti..F:Ml'S��ivC'ijy�'BdLR:k�F •�'lCll iLJ r'LIQ��i lt�uuY-__-•__
number, the identified location, and be of clear and reproducible quality.
✓ Lat$tudtx and longitudes mtttit repotted a6 being based tan either the •DYAD 27 or tiro NAD 83 data s}ntetns.
✓ Acceptable tnethodu of determiuir7g
FollowIocatlon latitudes and longitudes tmd their COntWonditg codes axe as
s
♦ Addrra4 Matc Lng (ADI]) • Digital or Raw Pboto Fattruction ti
- - - t Ar.. iwr PTu,rnU-phy �x iltk.+ tr:sad CUoxn¢-.s! %ri.i�•F r� �''�'
LOR a N.C. ATBvigg+,;L`zk � iC2 i .-ret's -
+-
t OV uVersiOrx #gym Townch;P yc. !roa Xiz.a�. (1.1m zf_.. ; -- i�c.wvic nett LLS
♦ Conr'ersiml &Qtn Universal Trans Mere 4t• 1
{UTM) + lip Code Ccnrtsoid {illx}
♦ Map inttcpretation by Digitaal or Waaual E_xttttstion (MAP)
I.ocati in accuracy Must be provided W the neaxe.�tt• unit {t.g., neat esr second, teruh of a second, etc.).
C. '_1 ml or fsx the attachm"t farm ayjd tho- ,,,4, :..�tz _�+� ��,t,.,rrr.�,;cc • e�,a�aYura�t Y[�YY"f eMrltt��li �npf -
to obtain the waterbody and dandfication intornr ti.'.
+r A list of the Division's regional offices, their county coverages :uld their courtacr infq=ation may L.e
downloaded from the wob site at: http://h2o.enr.,,tatr nc_uc/ndpul.
✓ The Division will not consider this attachmtnt: fora to be complete untiL it is Completed by tit* appmpriale
regional offloo.
To: Regional of"Fice: NCDENR-DW Ashevil{eRt ion2al Off-,Ge
Address ofregional office: 2096 LUS Hi wa 74 .--
City_ Swannanoa State: NC lip: 28778
Faosim:le number: ( 829 ) 299-7043
'k]easc provide me with the watarbody oame(sb stream index nutnbcr(s), and currentlpreposed
elissiG-tion(g) of the surlfnee waters that Are closest to attd dovvas]ape from the Iocatiok(s) wbbuere the
proposed residuah program activities are planned to occur, As ide>atiffed pu the attached map segment.
SignaYtwe of regional office staff.
FORM: RW 3CA 02!¢2.
Date:
Page L of 2 Attachment Order
i .I i DEC 28 2004

"action
F• 1
F•2
`F•3
F4
OIQ
i
C offs LaRidil ILongitude Location Location I,ocallon 'atcrbodY ubbasi� and
Datiw Method Accuracy Stream Index No,
' Cade
(!o Be Coraplefed.By J)W ?�'
tvfrr'�3,,�1
335' ?a.S' h` El° 51' 03.34"
1VAD 27
NIA
1 "
S1' GD35" ti
NAD 27
MAP
t 1„
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3A35'3? Eb"tiT
::° 30' 2.17"
NAD'27
MAP
� 1 IF
14iwba'eal
35'7S'3744''V
50'3"41"�
NAD
hdAI'
1"
Mro� l
--�1r:—
3: 4U` 2? ES' +�
'.�° 91' 32.35"
NAD 27
1P
t 1 "
P.iiHytie�
ti'-r _
Sift'' 4
—•--
�° 51' 58.�44"
NAD 27
MAp
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Y 1 1 41,15 1•
2414D 27
` 7viAP
kicl°t'elhick
?I° S 1' 23.25" �
NdD 27
NEAP
i'51'22,95"V
NAD 27
hitlA
9
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NAD 27
MAP
rir,I.t?"':}:. 4'a:
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N_AO27
hihY
1 (I
*** END OF FOR1111111CA 02103 **19
page 2 ci2
Current and
Proposed Class
o Be Completed By,
D;VQ)
Attachment Order 3-a
119.1
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IN

F7F3r W 04 17-79p
Rmnr:h Rmr-ldimls 9M51 OMAI p4
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k
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IN
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TjSGS Dy5aMvW, Norfh Carojgua 7.5 Njinute
City of mariou
RTB Land ApplicAtioij pjvgram
I Jelin FhUcr Farm
D tE-04
:I & �Ojm;s� LLC 2DbL di
USGS
TIO"
Map

Finn ?7 G4 l?,?Rr5- FN-D'—'q
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e 4eld Q-23
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J.
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it
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To
USGS Glee Alpinc7 N61r CarWins 7.6 Minute
WALL JLWPOM= VORWAUSS
NUcmn W.. city Ormarion
R7M Land App&ztfou Program
uA-L 1� FAi7�
Man

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Location County Lattitude Longitude Laratioa location
ID
Lcrat�oa
i� atert�ad3� Subbssin and
Current
S
Dahun Method
Accuracy
3tream Index No.
aad
prq•osad Class
�
-�
Code
inn °e �'�omgJetea!!z}D�P]h
��aBi' Complcfed Bp
P-1 Mitchell 350 52' 26.881, N 8P 03' 26.1?TAD 27 J JAg
X
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FORM. RWSCA 02102
6n or Fol�}I RtivSt^A azn;
Page2of2
Cad TeatA-der3-a
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UGG w U4 Izaip tsrancn Resnais
gal ULknl P.d
USGS 8
SCALLI:
J39A'Wr4,UV.*
1PA7-F. -
Dw-()4
Fine and Little Switzerfand, rloxilt C"Ima 7.5 MiAxde TopWaphic Quz
T*wA of Spruce Pine
RRA,r4CH Land AppNeation Program
Tommy Phillips Farm
Sc 91 2(KU47
VsGs
TOPO
Map;

WA rFRQ
Michael F. Easley, Governor
�oF
(�
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
\�
�^
Alan W. Klimek, P. E. Director
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
Asheville Regional Office
WATER QUALITY SECTION
May 18, 2004
Mr.Robert Boyette, City Manager
City of Marion
Post Office Drawer 700
Marion, North Carolina 28752
SUBJECT: Compliance Evaluation Inspection
City of Marion
Residuals Land Application Program
Permit No: WQ0019960
McDowell County
Dear Mr. Boyette:
Enclosed please find a copy of the Compliance Evaluation Inspection form from the inspection
conducted on May 11, 2004. Janet Cantwell and myself of the Asheville Regional Office conducted
the Compliance Evaluation Inspection. The facility was found to be in Compliance with permit
WQ0019960.
Please refer to the enclosed inspection report for additional observations and comments. If
you or your staff have any questions, please call me at 828/296-4500.
Sincerely,
Bev Price
Environmental Specialist
Enclosure
cc: Larry Carver, ORC; City of Marion WWTP, PO Drawer 700, Marion, NC 28752
Central Files
Asheville Files
A
am
2090 U.S. 70 Highway Swannanoa, North Carolina 28778 Telephone [phone] Fax [phone] Customer Service 1-877-623-6748

Permit: WQ0019960
SOC:
County: McDowell
Region: Asheville
Compliance Inspection Report
Effective: 04/24/02 Expiration: 06/30/06 Owner: City of Marion
Effective: Expiration: Facility: City of Marion Residuals Land Application
Program
Post Office Drawer 700
Contact Person: J Robert Boyette
Directions to Facility:
Primary ORC: Certification:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Marion NC 28752
Phone: [phone] Ext.
Phone:
Phone:
Inspection Date: 05/11/2004 Entry Time: 09:38 A Exit Time: 12:00 PM
Primary Inspector: Janet Cantwell Phone: [phone] Ext.
Secondary Inspector(s)
Beverly Price Ayv4 d4v Phone: [phone] Ext.
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ■ Compliant 0 Not Compliant '
Inspection Summary:
Southern Soil Builders (SSB) Inc., is currently providing services for the City of Marion Residuals Land Application program. The I
contact for SSB is David Key: Cell#336-957-7869; 336-957-8909; Fax#[phone]; 958 Hoots Road, Roaring River, NC 28699.
The records maintained by Larry Carter (City of Marion WWTP) and David Key are well kept and the data appeared accurate. The
residuals program appears to be well maintained.
Page: 1
i
{

• �
i
I
Permit: WQ0019960 Owner - Facility: City of Marion - City of Marion Residuals Land Application
Program
Inspection Date: 05/11/04 Inspection Type: Compliance Evaluation
i
IXRS
Land Application
Yes_
No
NA NE
Record Keening
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?
❑
❑ 0
Comment:All records appear to be in order and up to date. Records are kept in a green 3-ring binder with permit number
written on the spine.
Yes
No
NA NF
Pathooen and Vector Attraction
a. Fecal coliform SM 9221 E (Class A or B)
M ❑
❑ ❑
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)
❑ ❑
0 ❑
Temperature corrected
❑
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
❑ ❑
❑
e. Time/Temp on:
❑ ❑
MCI
Digester (MCRT)
Compost
❑
Class A lime stabilization
❑
f. Volatile Solids Calculations
❑
❑ ❑
g. Bench -top Aerobic/Anaerobic digestion results
❑ ❑
❑
Comment:The contract lab (PACE Analytical Services, Inc.) had the Fecal Coliforrn Method number listed as SM
9221 B/E. The correct notation should have been SM 9221 E. Gary Francies (Laboratory Auditor for the Asheville
Regional Office) contacted PACE concerning the discrepancy. PACE checked their records and confirmed the method
number.
Yes
No
NA NF
Treatment
Check all that apply
Aerobic Digestion
0I
Anaerobic Digestion
❑
Alkaline Pasteurization (Class A)
❑
i
Alkaline Stabilization (Class B)
❑
Page:2

Permit: WQ0019960 Owner - Facility: City of Marion - City of Marion Residuals Land Application Program
Inspection Date: 05/11/04 Inspection Type: Compliance Evaluation
Treatment Yes No NA NE
Compost ❑
Drying Beds ❑
Other ❑
Comment:
Sam In ina Yes No NA NE
Describe sampling: Plastic bucket is used to collect samples. Samples are collected from 7 different locations in the
digester. A composite sampler is used to collect samples for TCLP analysis.
Is sampling adequate? MOOD
Is sampling representative? M ❑ ❑ ❑
Comment:
Transport
Is a copy of the permit in the transport vehicle?
Yes No
❑
NA
❑
NE
❑
Is a copy of the spill control plan in the vehicle?
No
❑
❑
Is the spill control plan satisfactory?
M ❑
❑
❑
Does transport vehicle appear to be maintained?
❑
❑
❑
Comment:
Yes No NA NE
Land Application Site —
Y
Is a copy of the permit on -site during application events? ❑ ❑ ❑
Is the application site in overall good condition? ❑ ❑ ❑
Is the site free of runoff/ponding? ❑ ❑ ❑
If present, is the application equipment in good operating condition? ❑ ❑ ❑
Are buffers being maintained? ❑ ❑ ❑
Are limiting slopes buffered?
10% for surface application
0000
18% for subsurface application •
0000
Are there access restrictions and/or signs?
0 ❑
❑ ❑
Is the application site free of odors or vectors?
❑
❑ ❑
Have performance requirements for application method been met?
For injection?
❑ ❑
❑
For incorporation?
❑ ❑
❑
Does permit require monitoring wells?
❑
Is application occurring at the time of the inspection?
M ❑
Comment:The discharge tube on the spreader was loose. The discharge tube was secured on site. The application
site was enclosed with barbed wire fence.
Page: 3