NC0021733_NOV2023PC0252_Response_20230728

TOWN OF MARSHALL
180 South Main Street • PO Box 548• Marshall, NC 28753 • Phone [phone] • Fax (828)
649-3413
July 28, 2023
Mara Chamlee
Facility Inspector, Division of NC Water Resources
Dear Ms. Chamlee,
Please accept this letter as reply regarding the Town of Marshall's wastewater treatment NOV
received electronically on June 30, 2023 as a result of the the May At", 2023 inspection.
The Town of Marshall reached out to the North Carolina Rural Water Association for assistance.
On July 61h and July 10'h, Mr. Troy Cassidy with NCRWA visited the treatment facility to assist
us in rectifying the compliance issues at hand.
Mr. Cassidy has worked with the Town staff and consultants to devise a plan of action with
regards to the clarifier arm rack repair. Solids levels will need to be reduced in order to perform
the necessary repair. We are reaching out to Synagro to consider liquid haulers for getting solids
down quickly, and we are comparing that cost to the method of using a portable belt press to
press and dewater additional sludge for a temporary period.
The Town will be collecting MLSS samples weekly and performing Settleometer daily to
monitor the solids reduction process.
The Town is ordering parts for the clarifier rake so the parts will be available when needed.
Because the W WTP does not have any redundancy in place the steps taken will be a challenge
and complete bypass of the clarifier will most likely be necessary. A complete bypass will
shorten the detention time of the chlorine disinfection; however, samples for Fecal Coliform and
TSS will be collected during the bypass.
Below are the steps to be taken to initiate the plan of repair:
1. Waste and haul (or use belt press dewatering) until solids are below or around 4500
MLSS and Settleometer is below or around 450.
2. Ensure all parts are on hand for repair, including any tools required for repairs.
3. Ensure Digester is empty in order to waste out solids from bottom of clarifier when
proceeding to service clarifier.
4. Locate and verify valve is present to isolate ditch and be able to shut off flow to clarifier.
5. Set up bypass pump from oxidation ditch and be able to shut off flow to clarifier.
6. Turn off rotors and allow ditch to settle out.
7. Shut down valve from oxidation ditch to clarifier.
8. Begin to run bypass pumps once ditch has begun to settle.
9. Ensure chlorine and de -chlorination has been boosted to offset shortened detention times.

10. Have second pump in clarifier pumping down clear liquids from top of clarifier, while
wasting solids from bottom into empty digester.
11. Once clarifier has been pumped down enter confined space and begin all repairs.
12. Estimated time of repair from draining tank to finishing repairs will be approximately
five hours.
13. The Town is considering contracting the repair operations with a general contractor who
will have necessary equipment to perform all repairs.
Additional issues brought up in the NOV inspection report:
"LTV disinfection taken out of service." - Mr. Byers has stated that the UV system was
taken out of service prior to him being the ORC. This was noted back in 2009 but it is
uncertain if a permit modification was done prior to the system being taken out of
service. The Town is consulting with our engineering firm to discuss the possibility of
rehabilitating the current UV or designing a new Chlorine Contact Chamber with
adequate detention time. The DWR will be kept updated with this process. Please
inform the Town if it needs to address with any permit modifications or if modifications
were previously permitted.
2. "Drying Bed out of service" — The drying beds were taken out of service in 2009, when
Mr. Byers took over as ORC. The drying beds to not need to be utilized because current
practice of belt press dewatering is performed. Please inform the Town if it needs to
address with any permit modifications or if modifications were previously permitted.
3. "Effluent discharge pipe." —The effluent disposal point of entry will be maintained in a
manner proper for an inspection to occur.
Beyond the immediate repairs, the Town continues to pursue external funding for longer -term
upgrades to the WWTP. In cooperation with Madison County, the Town made a legislative
request at the beginning of the year for $15 million to assist with sewer system upgrades for the
Town of Marshall and Town of Mars Hill, and the Town is pursuing additional grant funding,
either in lieu of, or to augment, funds from a legislative appropriation.
Mr. Troy Cassidy with NCRWA will be providing additional technical service and training to
our Town. The Town intends to take swift action to resolve all issues. The Town would like to
thank DWR for the information that was provided which will enable the Town to improve
management of its facilities in the future.
Sincerely,
Forrest Gilliam
Town Administrator