WQ0003698_Site assessment scope of work and schedule_20230501

May 1, 2023

Anchor QEA of North Carolina, PLLC 231 Haywood Street Asheville, North Carolina 28801 828.281.3350
2023-0501 City of Marion Response to Permit Condition I(1) revised scope to include SW and Domestic Well Sampling
Brett Laverty
North Carolina Department of Environmental Quality
Water Quality Regional Operations
2090 U.S. Highway 70
Swannanoa, North Carolina 28778
Re: Scope of Work and Schedule Response to Permit WQ0003698 Condition I.1 Corpening Creek Surface Disposal Unit McDowell County, North Carolina
Dear Mr. Laverty:
Anchor QEA of North Carolina, PLLC, on behalf of the City of Marion, is submitting this scope of work
and schedule to address the requirements in Section I (1) of Permit WQ0003698 1 (the Permit), issued in
August 2022, and the requirements outlined in the March 2022 Notice of Violation and Intent to
Enforce2 (NOVIE). These documents are provided as Attachments A and B and pertain to the property
formerly used for surface disposal of residual wastes (biosolids), located southeast of College Drive in
Marion, North Carolina (Site; Figures 1 and 2).
The scope of work and schedule is required to address Section I (1) of the Permit; however, several
requirements related to the NOVIE must be addressed as well. The requirements outlined in the Permit
and the NOVIE that must be completed are as follows:
1. Permit Requirements:
a. Prior to August 1, 2024, the Permittee shall complete a Site assessment to determine the
extent of the waste boundaries associated with the surface disposal of residuals activities
covered under this permit.
i. A survey of the Site depicting the horizontal and vertical delineation of the waste
boundaries for all surface disposal units (SDUs) on Site. This survey shall be
recorded in the McDowell County Register of Deeds
ii. A delineation of the compliance and review boundaries for these waste boundaries
in accordance with 15A NCAC 02L.0107, 02L.0108, and Conditions II.6. and II.7.
iii. The condition/depth of the cover material for each SDU

1 City of Marion, Corpening Creek Surface Disposal Unit Water Quality Permit No. WQ0003698, August 1, 2022, North Carolina Department of Environmental Quality, Division of Water Resources
2 Notice of Violation and Intent to Enforce, NOV-2022-LV-0130, March 3, 2022, North Carolina Department of Environmental Quality,
Division of Water Resources
May 1, 2023 Page 2
iv. The vertical separations between the bottoms of the SDUs and the seasonal high
water table (SHWT)
v. The approximate volumes of residuals contained in each SDU
vi. Documentation of any solid waste material in the vicinity of the SDUs that does not
originate from the activities covered in this permit, and an identification of where
this material was found
2. NOVIE Requirements:
a. At or beyond a review boundary: demonstrate, through predictive calculations or
modeling, that natural Site conditions, facility design, and operational controls will
prevent a violation of standards at the compliance boundary. Alternately, a plan may be
submitted for alteration of existing Site conditions, facility design, or operational controls
that will prevent a violation at the compliance boundary and implement that plan upon
its approval by the Secretary.
b. Assess the cause, significance, and extent of the violation of standards and submit the
results of the investigation and a plan and proposed schedule for corrective action.
c. The Site assessment shall include the following:
i. The source and cause of contamination
ii. Any imminent hazards to public health and safety and actions taken to mitigate
them
iii. All receptors and significant exposure pathways
iv. The horizontal and vertical extent of soil and groundwater contamination and all
significant factors affecting contaminant transport
v. Geological and hydrogeological features influencing the movement, chemical, and
physical character of the contaminants
Anchor QEA has reviewed these requirements and the existing Site conditions and has discussed
these requirements with the City of Marion and the DEQ to develop a scope of work and schedule
that will address them. The details of the scope of work follow.
Background
From 1987 to 2001, the City of Marion’s SDUs received biosolid wastes from the Corpening
Creek Wastewater Treatment Plant (WWTP) and from the Catawba River WWTP under the Permit. The
Site stopped receiving biosolid wastes in 2001, and the facility was closed in 2002. The Site is currently
under a post-closure care program. Biosolid wastes were also received under previous permits from
1981 to 1987.
Prior to developing the scope of work, Anchor QEA reviewed Site data to understand existing Site
conditions and conducted a field reconnaissance on December 21, 2022, to observe the existing
May 1, 2023 Page 3
SDUs and to locate other, unpermitted SDUs. Figures 2 through 14 summarize the existing Site
conditions and form the foundation of the Conceptual Site Model (CSM) for the Site.
• Figure 2 displays the current Site layout following a Site reconnaissance field visit.
• Figures 3 through 6 provide a summary of historical monitoring results, with sampled
groundwater locations color-coded based on the largest magnitude of constituent detections
relative to the 2L groundwater standards.3
• Figures 7 through 10 provide concentration-versus-time graphs of the constituents that have
exceeded the 2L groundwater standards at some time on the Site.
• Figures 11 through 14 provide schematic cross-sections across four transects and show the
general understanding of groundwater migration across the Site.
Data Gaps Analysis
A data gap analysis based on Anchor QEA’s review of background data is presented in Table 1.
Figure 15 graphically summarizes the data gaps in context of the D-D’ cross-section shown in
Figure 14.
Proposed Scope of Work
The scope of work comprising the following tasks is proposed for implementation to collect the data
needed to fill data gaps and allow completion of the requirements previously outlined. The tasks are
grouped into work phases. As each work phase is completed, the CSM will be updated and consulted
with regards to the data requirements of subsequent tasks. If the review of the CSM suggests that
more or less data are needed, the scope of subsequent tasks may be altered.
Scope of Work
Phase 1 – Initial Risk-Based Assessment
Anchor QEA will identify receptors within 1,500 feet of the SDUs and show their position on a Site
map.
Surface Water Sampling
One known receptor is Youngs Fork, which flows toward the southeast along the eastern boundary
of the Site. Anchor QEA will assess the stream by walking its length adjacent to the site and looking
for areas of potential groundwater discharge (seeps). The identified seeps will be sampled using
methods appropriate for preserving sample integrity. In addition, a surface water sample will be
collected at 250-foot increments along the stream. The collected samples will be analyzed for the
suite of parameters listed in Table 2.

3 2L Groundwater Standards are from the North Carolina Administrative Code, Subchapter 2L – Groundwater Classifications and
Standards.
May 1, 2023 Page 4
Water Supply Well Survey and Sampling
Anchor will complete a water supply well survey of the area by identifying properties that do not
have a municipal water supply connection. A water supply source questionnaire will be sent to the
property owners to request permission to sample their wells and to request well construction details
if known. Up to four supply wells will be sampled based on proximity to the SDUs, well construction
details, and owner response. The collected samples will be analyzed for the suite of parameters listed
in Table 2.
Reporting
At the completion of Phase 1, a report summarizing the field activities, analytical results, and an
update to the Site CSM will be provided the DEQ.
Phase 2 – Initial Land Clearing and Geophysics
Initial Land Clearing
Anchor QEA will oversee initial land clearing to provide access to the SDUs identified in Figure 16 as
part of the preliminary SDU investigation. The land clearing is required so that drilling and
earthmoving equipment can access the SDUs and allow the assessment activities to be performed.
Surface Geophysics
Surface geophysics will be performed (electromagnetics and ground penetrating radar) to identify
the potential for other wastes besides wastewater biosolid wastes within the boundaries of the SDUs
and the pre-1981 waste disposal area (WDA). The geophysical survey will be performed along a grid
that covers the SDUs to be assessed. The surface geophysics will assist in providing the horizontal
extent of the SDUs and will be used to plan boring locations for the next phase of work.
Reporting
At the completion of Phase 2, a report summarizing the field activities, the results of the geophysical
evaluation, and an updated CSM will be provided to DEQ. The report will include a map showing the
locations of geophysical anomalies and potential boring locations.
Phase 3 Preliminary Surface Disposal Unit Assessment
Select SDU and Pre-1981 WDA Soil Borings for Preliminary Assessment
To determine the vertical extent of the SDUs and the WDA and their separation from the SHWT, one
soil boring will be advanced in the center of each SDU selected for assessment and two will be
advanced in the WDA. The assessment will be performed using a direct-push drill rig 4, to a depth of
10 feet below the water table (Figure 16). Soil returns will be described. A sample of the biosolid
waste material from near the bottom of the SDU and a sample from 5 feet below the bottom of the

4 At locations were a direct-push drill rig cannot reach the water table, a sonic drill rig may be used.
May 1, 2023 Page 5
biosolid waste will be collected. These samples will be containerized and stored should they be
required for later analysis. Two of the SDU boring samples, corresponding to the thickest biosolid
waste deposits, will be submitted for analysis. The two borings in the WDA will be performed using a
direct-push drill rig5 to a depth of 10 feet below the water table (Figure 16). Soil returns will be
described. A sample of the waste material from near the bottom of the WDA and a sample from
5 feet below the bottom of the waste will be collected.
All the borings will be converted to 1-inch diameter temporary wells to allow for groundwater
elevation measurements. Four of the temporary wells will be sampled. The biosolid waste, WDA
waste, soil, and groundwater samples will be analyzed for volatile organic compounds, metals, and
nutrients as indicated in Table 2.
Horizontal extent at the SDUs will be based on the geophysical results and by hand auger or other
hand digging tools (handheld power auger or similar). Hand digging methods will be used to
advance shallow borings starting 10 feet from the center of the SDU and moving outward at 10- or
20-foot intervals along two perpendicular transects until biosolid waste is not found. This will result
in four locations defining the horizontal extent of the SDUs: two will define the short axis of an SDU,
and two will define the long axis of the SDU. The four boundary points of each SDU will be flagged
for surveying at a later time.
The temporary wells will also be used to collect a soil vapor sample to assess the potential for
methane or other landfill gasses. The temporary wells will be constructed in a manner that will allow
soil gas to enter the sand pack above the water table and will allow a soil vapor sample to be
collected at the well head.
Revise Conceptual Site Model
The receptor assessment data, geophysical data, and data from the SDU boring evaluation will be
reviewed to inform the following:
• Potentiometric surface
• Horizontal extent of the SDUs
• Thickness of the SDUs
• Estimated volume of waste
• Separation of the bottom of the SDUs from the SHWT
These determinations will be incorporated into the CSM and used to evaluate next steps, which may
include additional assessment of SDUs in other areas of the site or determination of actions required
to bring the assessed portion of the Site into compliance.

5 At locations were a direct-push drill rig cannot reach the water table, a sonic drill rig may be used.
May 1, 2023 Page 6
Reporting
Anchor QEA will provide the DEQ with a summary of the collected data. The data will be presented
within the context of the CSM. Discussions of how the collected data address the actions required by
DEQ to achieve compliance will also be presented.
Phase 4 – Assess Remaining Surface Disposal Units in the Northern Portion of the Site
The SDUs in the northern portion of the Site will be assessed as described in Phases 2 and 3.
Completion of Phase 4 will result in all the Site SDUs having been assessed. The data collected from
Phases 1, 2, 3, and 4 will be combined to update the CSM, which will be used to determine the
remaining work to be performed to meet the requirements of the Permit and the NOVIE.
Phase 5 Additional Assessment Work and Remaining Requirements
The scope of the additional assessment work will be based on the results of Phases 1 to 4 and will
include the following:
• Installation of additional borings (number to be determined) to provide groundwater
elevation, chemistry, and hydraulic data. Some borings may be completed as review boundary
or compliance boundary wells.
• Modeling or predictive calculations to inform remedial alternatives
• Development of a Performance Monitoring Plan
• Design of a Cover System
Schedule
As part of the requirement for Permit condition I (1), an implementation schedule has been
developed and is presented in Table 3. Key dates from the Permit condition I (1) are as follows:
• Prior to August 1, 2024 per Permit condition I(2): due date for completion of assessment
activities
• August 30, 2024 per Permit condition I(4): due date for submittal of Performance Monitoring
Plan
• January 27, 2025 per Permit Condition I(3): due date for submittal of the final Cover System
design
Because of financial constraints, the City of Marion will not be able to fund the assessment at a
capital expenditure rate that will allow adherence to the prescribed schedule. Therefore, the City of
Marion would like to perform the assessment activities over the following 5-year period:
• July 2023 to June 2024: Phase 1 – Initial Risk-Based Assessment
• July 2024 to June 2025: Phase 2 - Initial Land Clearing and Geophysics
• July 2025 to June 2026: Phase 3 - Preliminary Surface Disposal Unit Assessment
• July 2026 to June 2027: Phase 4 – Assess Remaining Surface Disposal Units in the Northern
Portion of the Site
May 1, 2023 Page 7
• July 2027 to June 2028: Phase 5: Additional Assessment Work and Remaining Requirements
As progress is made through completion of Phases 1 to 5, the City will try to identify revenue sources
that can be used to offset the assessment cost and allow an expedited schedule.
Closing
On behalf of the City of Marion, Anchor QEA appreciates DEQ’s review of the proposed scope of work
and schedule and is prepared to answer additional questions if they arise.
Sincerely,

Chuck Pippin, PG, RSM
Senior Managing Geologist
cc: Brant Sikes, City of Marion
Attachments
Figure 1 Location Map
Figure 2 Site Layout
Figure 3 Summary of Groundwater Sampling Data - Ammonia Figure 4 Summary of Groundwater Sampling Data - Nitrate
Figure 5 Summary of Groundwater Sampling Data - Manganese
Figure 6 Summary of Groundwater Sampling Data - Iron
Figure 7 Time Concentration Trends for MW-1R
Figure 8 Time Concentration Trends for MW-2
Figure 9 Time Concentration Trends for MW-3
Figure 10 Time Concentration Trends for MW-4
Figure 11 Preliminary Cross-Section A to A’ Figure 12 Preliminary Cross-Section B to B’
Figure 13 Preliminary Cross-Section C to C’ Figure 14 Preliminary Cross-Section D to D’
Figure 15 Summary of Data Gaps Presented on Preliminary Cross-Section D to D’ Figure 16 Proposed Phased Approach
Table 1 Data Gaps Evaluation Table 2 List of Analytes for Groundwater and Soil/Biosolids
Table 3 Implementation Schedule
Attachment A Permit No. WQ0003698 Attachment B Notice of Violation and Intent to Enforce, NOV-2022-LV-0130

Figures
Publish Date: 2023/02/14, 10:51 AM | User: cpippinFilepath: Q:\Jobs\City_of_Marion_NC_2746\Maps\Fig1_Location_cgp.mxd
Figure 1Site LocationSurface Disposal Unit - Permit No. WQ0003698City of Marion
%
Site Location
[0 2,000
Feet
Legend
Site Boundary
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@<
@<
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C
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MW-4
MW-3
MW-2
MW-1RMW-1(Abandoned)
SDU 1
SDU 2
Pit A -1
Pit B
Pit C
Pit A-2SDU 4, 5, 6 & 7
SDU 3
SDU 8 & 9
SDU 10
Pit G-1
Pit D
Pit F-1
Pit F-2
Pit H
Location of Past WWT Aerator
Pit G-2
Pit G-3
SDU 11 Pre-1981 Disposal Area
A
D'
D
C'
C
B'
B
A'
YOUNGSFORK
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Youngs Fork
Publish Date: 2023/03/09, 11:24 AM | User: cpippinFilepath: Q:\Jobs\City_of_Marion_NC_2746\Maps\Fig2_SitePlan_cgp.mxd
NOTES:1. SDU: Surface Diposal Unit2. Unpermitted SDUs identified during Anchor QEAfield reconnaissance performed on December 21, 2022,by review of historical aerial photographs, and reviewof locations from the North Carolina Department ofEnvironmental Quality (DEQ).
Figure 2Site LayoutSurface Disposal Unit - Permit No. WQ0003698City of Marion
[
Legend
")Abandoned Well
@<Monitoring Well
Compliance Boundary
City of Marion Property Boundary
Surface Water
Access Road
Unpermitted SDU
Permitted SDU
Cross-Section Reference Line
0 200 400100
Feet
!(
!(
!(
!(
")
MW-2
MW-1Abandoned
MW-4
MW-3
MW-1R
Pub lish Da te : 2023/02/14, 3:55 PM | Use r: cpippinFile pa th: Q:\Job s\City_of_Ma rion_N C_2746\Ma ps\Fig 3_GW_Sa m pling _Am m onia .m xd
Figure 3Summary of Groundwater Sampling Data - Ammonia
[
%
MW-1RBe twe e n 1984 a nd 2022 sam ple d 117 tim e s
AmmoniaMa xim um - 8.9 mg/L (July 2002)Av e ra g e - 0.20 m g /L11/3/2022 - %
MW-4Be twe e n 2001 a nd 2022 sam ple d 52 tim e s
AmmoniaMa xim um - 9.15 mg/L (July 2002)Av e ra g e - 0.33 m g /L11/3/2022-
%MW-3Be twe e n 1984 a nd 2022 sam ple d 116 tim e s
AmmoniaMa xim um - 9.16 mg/L (July 2002)Av e ra g e - 0.18 m g /L11/3/2022 -
%
MW-2Be twe e n 1984 a nd 2022 sam ple d 118 tim e s
AmmoniaMa xim um - 10.0 mg/L (Ma rch 1996)Av e ra g e - 3.4 mg/L11/3/2022-
<0.1 m g /L
<0.1 m g /L
5.4 mg/L
<0.1 m g /L
0 320
Fe e t
Surface Disposa l Unit - Pe rm it N o. WQ0003698 City of Ma rion
NOTES:1. 15A N CAC 2L Groundwa te r Sta nda rdAm m onia - 1.5 m g /L.2. Sludg e Disposa l Are a s (SDU) Ide ntifie d b y a nnota te dm a p re ce iv e d from DEQ, re v ie w of a e ria l photog ra phy,and fie ld re conna issa nce .3. DEQ - N orth Ca rolina De partm e nt of Env ironm e nta lQua lity.4. Bold indicate s conce ntra tion g re a te r tha n 2LGroundwa te r Sta nda rd5. m g /L: m ilg ram pe r lite r
Legend
Unpe rm itte d SDU
Pe rm itte d SDU
City of Ma rion Prope rty Bounda ry
Curre nt Com plia nce Bounda ry
Summary of 2L Exceedance for MostRecent Analytical Data
!(N ot De te cte d
!(> 1x 2L Sta nda rd
!(> 10x 2L Sta ndard
!(> 100x 2L Standa rd
!(≤ 2L Standa rd
Ab a ndone d We ll")
!(
!(
!(
!(
")
MW-2
MW-1Abandoned
MW-4
MW-3
MW-1R
Pub lish Da te : 2023/02/14, 4:04 PM | Use r: cpippinFile pa th: Q:\Job s\City_of_Ma rion_N C_2746\Ma ps\Fig 4_GW_Sa m pling _N itra te _cg p.m xd
Figure 4Summary of Groundwater Sampling Data - Nitrate
[
%
MW-1RBe twe e n 1984 a nd 2022 sam ple d 117 tim e s
NitrateMa xim um - 25.0 mg/L (Ma rch 1999)Av e ra g e - 0.30 m g /L11/3/2022 - 0.068 m g /L
%
MW-4Be twe e n 2001 a nd 2022 sam ple d 52 tim e s
NitrateMa xim um - 2.9 m g /L (N ov 2022)Av e ra g e - 0.31 m g /L11/3/2022-
%MW-3Be twe e n 1984 a nd 2022 sam ple d 116 tim e s
NitrateMa xim um - 160.0 mg/L (Ma rch 1999)Av e ra g e - 4.8 m g /L11/3/2022 -
%
MW-2Be twe e n 1984 a nd 2022 sam ple d 118 tim e s
NitrateMa xim um - 15.0 mg/L (Ma rch 1999)Av e ra g e - 0.25 m g /L11/3/2022-
2.90 m g /L
<0.040 m g /L
10 m g /L
0 300
Fe e t
Surface Disposa l Unit - Pe rm it N o. WQ0003698 City of Ma rion
NOTES:1. 15A N CAC 2L Groundwa te r Sta nda rdN itra te - 10 m g /L.2. Sludg e Disposa l Are a s (SDU) Ide ntifie d b y a nnota te dm a p re ce iv e d from DEQ, re v ie w of a e ria l photog ra phy,and fie ld re conna issa nce .3. DEQ - N orth Ca rolina De partm e nt of Env ironm e nta lQua lity.4. Bold indicate s conce ntra tion g re a te r tha n 2LGroundwa te r Sta nda rd5. m g /L: m ilg ram pe r lite r
Legend
Unpe rm itte d SDU
Pe rm itte d SDU
City of Ma rion Prope rty Bounda ry
Curre nt Com plia nce Bounda ry
Summary of 2L Exceedance for MostRecent Analytical Data
!(N ot De te cte d
!(> 1x 2L Sta nda rd
!(> 10x 2L Sta ndard
!(> 100x 2L Standa rd
!(≤ 2L Standa rd
Ab a ndone d We ll")
!(
!(
!(
!(
!(")
MW-2
MW-1Abandoned
MW-4
MW-3
MW-1R
Pub lish Da te : 2023/02/14, 4:11 PM | Use r: cpippinFile pa th: Q:\Job s\City_of_Ma rion_N C_2746\Ma ps\Fig 5_GW_Sa m pling _Ma ng a ne se .m xd
Figure 5Summary of Groundwater Sampling Data - Manganese
[
%
MW-1RBe twe e n 1984 a nd 2022 sam ple d 117 tim e s
ManganeseMa xim um - 0.43 mg/L (Ma y 2017)Av e ra g e - 0.007 m g /L11/3/2022 - %
MW-4Be twe e n 2001 a nd 2022 sam ple d 52 tim e s
ManganeseMa xim um - 0.21 mg/L (Ma y 2021)Av e ra g e - 0.03 m g /L11/3/2022-
%MW-3Be twe e n 1984 a nd 2022 sam ple d 116 tim e s
ManganeseMa xim um - 0.58 mg/L (N ov 2019)Av e ra g e - 0.043 m g /L11/3/2022 -
%
MW-2Be twe e n 1984 a nd 2022 sam ple d 118 tim e s
ManganeseMa xim um - 1.8 mg/L (N ov 2012)Av e ra g e - 0.127 mg/L11/3/2022-
0.0175 m g /L
0.086 mg/L
1.250 mg/L
0.0985 mg/L
0 300
Fe e t
Surface Disposa l Unit - Pe rm it N o. WQ0003698 City of Ma rion
NOTES:1. 15A N CAC 2L Groundwa te r Sta nda rdMa ng a ne se - 0.050 m g /L.2. Sludg e Disposa l Are a s (SDU) Ide ntifie d b y a nnota te dm a p re ce iv e d from DEQ, re v ie w of a e ria l photog ra phy,and fie ld re conna issa nce .3. DEQ - N orth Ca rolina De partm e nt of Env ironm e nta lQua lity.4. Bold indicate s conce ntra tion g re a te r tha n 2LGroundwa te r Sta nda rd5. m g /L: m ilg ram pe r lite r
Legend
Unpe rm itte d SDU
Pe rm itte d SDU
City of Ma rion Prope rty Bounda ry
Curre nt Com plia nce Bounda ry
Summary of 2L Exceedance for MostRecent Analytical Data
!(N ot De te cte d
!(> 1x 2L Sta nda rd
!(> 10x 2L Sta ndard
!(> 100x 2L Standa rd
!(≤ 2L Standa rd
Ab a ndone d We ll")
!(
!(
!(
!(
!(")
MW-2
MW-1Abandoned
MW-4
MW-3
MW-1R
Pub lish Da te : 2023/02/14, 4:16 PM | Use r: cpippinFile pa th: Q:\Job s\City_of_Ma rion_N C_2746\Ma ps\Fig 6_GW_Sa m pling _Iron.m xd
Figure 6Summary of Groundwater Sampling Data - Iron
[
%
MW-1RBe twe e n 1984 a nd 2022 sam ple d 117 tim e s
IronMa xim um - 81.0 mg/L (N ov 2001)Av e ra g e - 7.1 mg/L11/3/2022 - %
MW-4Be twe e n 2001 a nd 2022 sam ple d 52 tim e s
IronMa xim um - 110 mg/L (July 2003)Av e ra g e - 16.7 mg/L11/3/2022-
%MW-3Be twe e n 1984 a nd 2022 sam ple d 116 tim e s
IronMa xim um - 95.0 mg/L (July 2002)Av e ra g e - 6.5 mg/L11/3/2022 -
%
MW-2Be twe e n 1984 a nd 2022 sam ple d 118 tim e s
IronMa xim um - 170 mg/L (N ov 2001)Av e ra g e - 35.9 mg/L11/3/2022-
0.0869 m g /L
<0.0500 m g /L
27.100 mg/L
0.214 m g /L
0 300
Fe e t
Surface Disposa l Unit - Pe rm it N o. WQ0003698 City of Ma rion
NOTES:1. 15A N CAC 2L Groundwa te r Sta nda rdIron - 0.30 m g /L.2. Sludg e Disposa l Are a s (SDU) Ide ntifie d b y a nnota te dm a p re ce iv e d from DEQ, re v ie w of a e ria l photog ra phy,and fie ld re conna issa nce .3. DEQ - N orth Ca rolina De partm e nt of Env ironm e nta lQua lity.4. Bold indicate s conce ntra tion g re a te r tha n 2LGroundwa te r Sta nda rd5. m g /L: m ilg ram pe r lite r
Legend
Unpe rm itte d SDU
Pe rm itte d SDU
City of Ma rion Prope rty Bounda ry
Curre nt Com plia nce Bounda ry
Summary of 2L Exceedance for MostRecent Analytical Data
!(N ot De te cte d
!(> 1x 2L Sta nda rd
!(> 10x 2L Sta ndard
!(> 100x 2L Standa rd
!(≤ 2L Standa rd
Ab a ndone d We ll")
Figure 7Time Concentration Trends for MW-1R
Surface Disposal Unit -Permit No. WQ0003698City of Marion
Figure 8Time Concentration Trends for MW-2
Surface Disposal Unit -Permit No. WQ0003698City of Marion
Figure 9Time Concentration Tends for MW-3
Surface Disposal Unit -Permit No. WQ0003698City of Marion
Figure 10Time Concentration Trends for MW-4
Surface Disposal Unit -Permit No. WQ0003698City of Marion
1100
1120
1140
1160
1180
1200
1220
1240
1260
1280
1300
1320
1340
1360
1380
0 100 200 300 400 500 600 700 800 900 1000 1100Graphic Profile A Borings Features
Unknown Extents Requires Assessment
Unknown ExtentsRequires AssessmentRequires Partial Assessment
MW-4
A A’
Pit F-1 Pit G-2 Pit G-1 SDU 8&9
BH6
BH3
BH8
MW-4pH (6.5-8.5 SU): 5.9 SUAmmonia (1.5 mg/L): NDNitrate (10 mg/L): –3 mg/LIron (0.30 mg/L): NDManganese (0.050 mg/L): 0.086 mg/L
Notes: Historical soil borings based on Biosolids Evaluation. Marion Biosolids, Catawba Valley Engineering & Testing ( November 4, 2021) and on the 2008-2009 City of Marion Disposal Unit Investigation performed by the North Carolina Department of Environmental Quality. Water table inferred from borehole logging data and depth to water observed in monitoring wells. Inferred SDU: Surface disposal unit (SDU) surface extent estimated based on field observations and vertical extent based on boring log information. For locations where borings have not been advanced, the vertical extent is estimated based on boring from other locations and will require confirmation. SU: Standard Unitsmg/L: milligrams per liter
_______Highlighting indicates concentrations exceed the 2L groundwater standards.
Figure 11Preliminary Cross-Section A to A’
Surface Disposal Unit -Permit No. WQ0003698City of Marion
Depth to bedrock unknown
Top of transition zone unknown
Youngs Fork
Legend
The zone between ground surface and the top of transition zone is the referred to as the regolith, below the water table it is the saturated regolith. Groundwater flow through this zone is dominated by porous media flow.
The transition zone represents an interval of partially weathered rock and highly fractured rock. Groundwater flow through this zone is typically via a combination of porous media and fractures. This zone tends to be more transmissive than the saturated regolith.
Below the transition zone is the fractured bedrock. Flow through this portion of the aquifer is dominated by fracture flow through an interconnected fracture network.
Well Screen
Well Casing
Biosolids
---
---
Inferred SDU
Inferred Water Table
Inferred Top of Transition Zone
Inferred Top of Bedrock
Representation of Potential Groundwater Flow PathsSoil Boring
Compliance Boundary
Distance Along Section (feet) 2x Vertical Exaggeration
El
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SDU3-4-5-6-BH6
SDU3-4-5-6-BH3 projected from west
SDU3-4-5-6-BH2 projected from west
SDU3-4-5-6-BH12
SDU3-4-5-6-BH11
SDU3-4-5-6-BH8
SDU3-4-5-6-BH9 projected from west
1100
1120
1140
1160
1180
1200
1220
1240
1260
1280
1300
1320
1340
1360
1380
0 100 200 300 400 500 600 700 800 900 1000 1100
Graphic Profile B Boreholes FeaturesDistance Along Section (feet) 2x Vertical Exaggeration
B B’SDU 4-5-6-7 SDU 3 Pre 1981 Disposal Area
Figure 12Preliminary Cross-Section B to B’
Surface Disposal Unit -Permit No. WQ0003698City of Marion
Depth to bedrock unknown
Top of transition zone unknown
Youngs Fork
Borings with Hand Auger Refusal at Shallow Depth.
Requires AssessmentField Observation Suggest SDU 3 Located to the East
Legend
Notes: Historical soil borings based on Biosolids Evaluation. Marion Biosolids, Catawba Valley Engineering & Testing ( November 4, 2021) and on the 2008-2009 City of Marion Disposal Unit Investigation performed by the North Carolina Department of Environmental Quality. Water table inferred from borehole logging data and depth to water observed in monitoring wells. Inferred SDU: Surface disposal unit (SDU) surface extent estimated based on field observations and vertical extent based on boring log information. For locations where borings have not been advanced, the vertical extent is estimated based on boring from other locations and will require confirmation.
Compliance Boundary The zone between ground surface and the top of transition zone is the referred to as the regolith, below the water table it is the saturated regolith. Groundwater flow through this zone is dominated by porous media flow.
The transition zone represents an interval of partially weathered rock and highly fractured rock. Groundwater flow through this zone is typically via a combination of porous media and fractures. This zone tends to be more transmissive than the saturated regolith.
Below the transition zone is the fractured bedrock. Flow through this portion of the aquifer is dominated by fracture flow through an interconnected fracture network.
Well Screen
Well Casing
Biosolids
---
---
Inferred SDU
Inferred Water Table
Inferred Top of Transition Zone
Inferred Top of Bedrock
Representation of Potential Groundwater Flow PathsSoil Boring
El
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(
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)
1100
1120
1140
1160
1180
1200
1220
1240
1260
1280
1300
1320
1340
1360
1380
0 100 200 300 400 500 600 700 800 900 1000 1100
Graphic Profile C Features
Unknown Extent Requires Assessment
Unknown Extent Requires Assessment
MW-2
C C’Pre 1981 Disposal AreaMound Containing Pits A, B, & C
MW-2pH (6.5-8.5 SU): 6.4 SUAmmonia (1.5 mg/L): 5.4 mg/LNitrate (10 mg/L): NDIron (0.30 mg/L): 27.10 mg/LManganese (0.050 mg/L): 1.250 mg/L
Figure 13Preliminary Cross-Section C to C’
Surface Disposal Unit -Permit No. WQ0003698City of Marion
Depth to bedrock unknown
Top of transition zone unknown
Legend
Notes: Historical soil borings based on Biosolids Evaluation. Marion Biosolids, Catawba Valley Engineering & Testing ( November 4, 2021) and on the 2008-2009 City of Marion Disposal Unit Investigation performed by the North Carolina Department of Environmental Quality. Water table inferred from borehole logging data and depth to water observed in monitoring wells. Inferred SDU: Surface disposal unit (SDU) surface extent estimated based on field observations and vertical extent based on boring log information. For locations where borings have not been advanced, the vertical extent is estimated based on boring from other locations and will require confirmation. SU: Standard Unitsmg/L: milligrams per liter
_______Highlighting indicates concentrations exceed the 2L groundwater standards.
The zone between ground surface and the top of transition zone is the referred to as the regolith, below the water table it is the saturated regolith. Groundwater flow through this zone is dominated by porous media flow.
The transition zone represents an interval of partially weathered rock and highly fractured rock. Groundwater flow through this zone is typically via a combination of porous media and fractures. This zone tends to be more transmissive than the saturated regolith.
Below the transition zone is the fractured bedrock. Flow through this portion of the aquifer is dominated by fracture flow through an interconnected fracture network.
Well Screen
Well Casing
Biosolids
---
---
Inferred SDU
Inferred Water Table
Inferred Top of Transition Zone
Inferred Top of Bedrock
Representation of Potential Groundwater Flow PathsSoil Boring
Distance Along Section (feet) 2x Vertical Exaggeration
El
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(
f
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)
SDU1-BH14
SDU1-BH9
SDU1-BH11
SDU1-BH8 projected from west
SDU1-BH6 projected from west
SDU1-BH5 projected from west
SDU1-BH7 projected from west
SDU1-BH12 projected from west
1100
1120
1140
1160
1180
1200
1220
1240
1260
1280
1300
1320
1340
1360
1380
1400
0 100 200 300 400 500 600 700 800 900 1000 1100
Graphic Profile D Features Boreholes
MW-3
D D’SDU 1
MW-3pH (6.5-8.5 SU): 6.2 SUAmmonia (1.5 mg/L): NDNitrate (10 mg/L): 10 mg/LIron (0.30 mg/L): 0.21 mg/LManganese (0.050 mg/L): 0.099 mg/L
Figure 14Preliminary Cross-Section D to D’
Surface Disposal Unit -Permit No. WQ0003698City of Marion
Boring Terminated at 15.8 feet, did not Encounter Native Soils Below Biosolids at this Location
Depth to bedrock unknown
Top of transition zone unknown
Legend
Ground Surface
Notes: Historical soil borings based on Biosolids Evaluation. Marion Biosolids, Catawba Valley Engineering & Testing ( November 4, 2021) and on the 2008-2009 City of Marion Disposal Unit Investigation performed by the North Carolina Department of Environmental Quality. Water table inferred from borehole logging data and depth to water observed in monitoring wells. Inferred SDU: Surface disposal unit (SDU) surface extent estimated based on field observations and vertical extent based on boring log information. For locations where borings have not been advanced, the vertical extent is estimated based on boring from other locations and will require confirmation. SU: Standard Unitsmg/L: milligrams per liter
_______Highlighting indicates concentrations exceed the 2L groundwater standards.
Compliance Boundary
The zone between ground surface and the top of transition zone is the referred to as the regolith, below the water table it is the saturated regolith. Groundwater flow through this zone is dominated by porous media flow.
The transition zone represents an interval of partially weathered rock and highly fractured rock. Groundwater flow through this zone is typically via a combination of porous media and fractures. This zone tends to be more transmissive than the saturated regolith.
Below the transition zone is the fractured bedrock. Flow through this portion of the aquifer is dominated by fracture flow through an interconnected fracture network.
Native Soils Encountered Below Biosolids
Well Screen
Well Casing
Biosolids
---
---
Inferred SDU
Inferred Water Table
Inferred Top of Transition Zone
Inferred Top of Bedrock
Representation of Potential Groundwater Flow PathsSoil Boring
Distance Along Section (feet) 2x Vertical Exaggeration
El
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(
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)
Figure 15Summary of Data Gaps Presented on Preliminary Cross-Section D to D’
Surface Disposal Unit -Permit No. WQ0003698City of Marion
Legend
1.Vertical extent of the SDUs is not known.
2.Horizontal extent of the SDUs is not known.
3.Depth to the seasonal high-water table is not known across the site.
4.Geochemistry of the SDU residual materials is not fully characterized.
5.Vapor risk has not been fully characterized
6.Vertical and horizontal extent of groundwater contamination is not known.
7.Groundwater chemistry immediately downgradient of SDU is not known
8.Groundwater chemistry at the compliance boundary is unknown; additional analytical parameters may be required to support remedial design. This is to be determined.
9.Hydraulic data for the aquifer system is not known. Understanding hydraulic conductivity and transmissivity will be required for modeling or predictive calculations
10.Groundwater transport is not understood at this time. The monitoring well network is insufficient to understand groundwater migration across the site, except in very general terms. Additional wells, including potential bedrock monitoring wells will be required to understand the groundwater flow system.
1
3
4
5
6
8
9
10Notes: Historical soil borings based on Biosolids Evaluation. Marion Biosolids, Catawba Valley Engineering & Testing ( November 4, 2021) and on the 2008-2009 City of Marion Disposal Unit Investigation performed by the North Carolina Department of Environmental Quality. Water table inferred from borehole logging data and depth to water observed in monitoring wells. Inferred SDU: Surface disposal unit (SDU) surface extent estimated based on field observations and vertical extent based on boring log information. For locations where borings have not been advanced, the vertical extent is estimated based on boring from other locations and will require confirmation. SU: Standard Unitsmg/L: milligrams per liter
_______Highlighting indicates concentrations exceed the 2L groundwater standards.
2
Well Screen
Well Casing
Biosolids
---
---
Inferred SDU
Inferred Water Table
Inferred Top of Transition Zone
Inferred Top of Bedrock
Representation of Potential Groundwater Flow PathsSoil Boring
Distance Along Section (feet) 2x Vertical Exaggeration
SDU1-BH14
SDU1-BH9
SDU1-BH11
SDU1-BH8 projected from west
SDU1-BH6 projected from west
SDU1-BH5 projected from west
SDU1-BH7 projected from west
SDU1-BH12 projected from west
1100
1120
1140
1160
1180
1200
1220
1240
1260
1280
1300
1320
1340
1360
1380
1400
0 100 200 300 400 500 600 700 800 900 1000 1100
Graphic Profile D Features Boreholes
MW-3
D D’SDU 1
MW-3pH (6.5-8.5 SU): 6.2 SUAmmonia (1.5 mg/L): NDNitrate (10 mg/L): 10 mg/LIron (0.30 mg/L): 0.21 mg/LManganese (0.050 mg/L): 0.099 mg/L
Depth to bedrock unknown
Top of transition zone unknown
Ground Surface
Compliance Boundary
Distance Along Section (feet) 2x Vertical Exaggeration
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1
3
4
6
7
2
5
89
10
7
9
@<
@<
@<
@<
%
Phase 2
Land clearing
Surface Geophysics.
%
Phase 1
Sample surface water at 250 ft intervals (9-samples)
Walk creek and look for groundwater seeps andcollect samples if found (assume 4)
%Phase 1
Send questionaire to potential well owners.
Inquire about well construction, depth, and yield.
Collect samples from four wells dependent on construction, proximity to site, yield, and other hydrogeologic factors.
%
Phase 3
Boring placed in center of each SDU.
Sample waste and soils from 5-ft below waste. Continue boring to water table.
Set temporary well to get groundwater elevation and groundwater sample.
%
Phase 4
Land Clearing
Geophysics
Boring placed in center of each SDU.
Sample waste and soils from 5-ft below waste. Continue boring to water table.
Set temporary well to get groundwater elevation and groundwater sample.
%
Phase 5
Potential Monitoring Well Installationand Groundwater Sampling
Hydraulic Testing and Analysis
Modeling/Predictive Calculations
Establish Compliance Boundary
Finalize Compliance Monitoring Plan
Perform Site Survey and Update Site Map
Design Final Cover System
Publish Date: 2023/03/26, 12:32 PM | User: cpippinFilepath: Q:\Jobs\InternationalPaper_0720\IP_ClosedNCLandfills\Maps\2022\LF2_Slope_Regrade\Fig16_Phased_Approach.mxd
[0 500
Feet
LEGEND:
Site Boundary
@<Existing Monitoring Well
Unpaved Road or Path
Permitted and Unpermitted SDUs
Permitted and Unpermitted SDUs
Pre-1981 Waste Disposal Area
Stream Sample Locations
Potential Supply Well Location
Phase 1
Phase 2 & 3
Phase 4
Phase 5
Figure 16Proposed Phased Approach
Surface Disposal Unit - Permit No. WQ0003698City of Marion

Tables
Table 1
Data Gaps Evaluation
Data Gap 1 2 3 4–7 8, 9 10 A–C D, E F G
1. Horizontal Extent of SDU P Y N P P P N P P N N 
2. Vertical Extent of SDU Y Y N P N N N N N N N 
3. Separation of Bottom of
Waste from Groundwater High N N N N N N N N N N N 
4. Geochemistry of SDU Waste N N N N N N N N N N N 
5. Vapor Risk N N N N N N N N N N N 
6. Vertical and Horizonal Extent
of Groundwater Contamination N N N N N N N N N N N 
Install additional monitoring wells to characterize the
horizontal and vertical extent of contamination. Assess
stream for groundwater seep locations and collect
samples if present. Collect Surface water samples along
stream. Collect samples from nearby domestic wells.
7. Geochemistry of
Groundwater Immediately
Downgradient of SDU
N N N N N N N N N N N 
Using permanent and temporary monitoring wells
collect groundwater samples for metals, nutrients and
volatile organic compounds.
8. Geochemistry of
Groundwater at Compliance
Boundary
P P P P P P P P P P P 
Using permanent and temporary monitoring wells
collect groundwater samples for metals, nutrients and
volatile organic compounds.
9. Hydraulic Data N N N N N N N N N N N 
Use temporary and permanent wells to perform
hydraulic testing to characterize hydraulic parameters of
the aquifer.
Existing Data for Surface Disposal Unit Fulfills Data Gap?
Data Gap Description
The full horizontal extent has only been determined for SDU 2. The
other locations have are only partially (P) defined based on topographic
boundaries or have not been assessed or previously mapped
The vertical extent of the SDUs have only been defined for SDU 1 and
SDU 2. The extent for SDU 4-5-6-7 has only partially been defined. The
others have not be assessed
Depth to groundwater has not been assessed in the vicinity of each
SDU. A background well and three compliance wells located near the
downgradient property boundary are the only controls for groundwater.
There is no know hydraulic data (hydraulic conductivity and
transmissivity) for the groundwater aquifer.
Needs to be evaluated. Groundwater samples from a location
immediately downgradient of the SDU will provide a starting point for
evaluating groundwater transport and provide the data needed for
modeling the potential for attenuation of the contaminant plume
Present in three compliance monitoring wells; however, monitoring well
network needs to be evaluated for appropriate performance monitoring.
The vertical and horizontal extent of groundwater contamination has
not been determined. The only monitoring wells on Site are the
background well and three shallow compliance monitoring wells.
Surface Disposal Unit Pit
Pre-1981
Disposal
Site
Develop an assessment strategy based on soils borings
and geophysics.
Select soil borings will be converted to temporary
monitoring wells to provide groundwater elevations and
sampling opportunity. The resulting data will be used to
convert select temporary wells to permanent wells to
support a performance monitoring network.
Advance soil borings into SDU waste material to allow
characterization sampling.
With a drill rig on-site a soil vapor assessment can be
performed by field screening the drilling returns and the
head space of the temporary wells.
Historical sludge analysis is in the records, however, no data has been
discovered related to geochemical analysis of buried sludge. These data
will provide information on the source materials and will support
remedial design decision and modeling.
Needs to be evaluated. All of the SDUs and the debris area have
potential to generate methane gas from the degradation of organic
materials. Therefore the Site needs to be evaluated for methane gas.
Potential Next Steps
Strategies to Address Data Gap
Su
r
f
a
c
e

W
a
t
e
r

S
a
m
p
l
i
n
g
Su
p
p
y

W
e
l
l

S
a
m
p
l
i
n
g
So
i
l

B
o
r
i
n
g
/
S
a
m
p
l
i
n
g
Co
r
e

D
e
s
c
r
i
p
t
i
o
n
s
We
l
l

I
n
s
t
a
l
l
a
t
i
o
n

Hy
d
r
a
u
l
i
c

T
e
s
t
i
n
g
Gr
o
u
n
d
w
a
t
e
r

S
a
m
p
l
i
n
g
Va
p
o
r

S
a
m
p
l
i
n
g
Su
r
f
a
c
e

G
e
o
p
h
y
s
i
c
s
Surface Disposal Unit – Permit WQ0003698
City of Marion
Page 1 of 2
April 2023
Table 1
Data Gaps Evaluation
Data Gap 1 2 3 4–7 8, 9 10 A–C D, E F G
Existing Data for Surface Disposal Unit Fulfills Data Gap?
Data Gap Description
Surface Disposal Unit Pit
Pre-1981
Disposal
Site
Potential Next Steps
Strategies to Address Data Gap
Su
r
f
a
c
e

W
a
t
e
r

S
a
m
p
l
i
n
g
Su
p
p
y

W
e
l
l

S
a
m
p
l
i
n
g
So
i
l

B
o
r
i
n
g
/
S
a
m
p
l
i
n
g
Co
r
e

D
e
s
c
r
i
p
t
i
o
n
s
We
l
l

I
n
s
t
a
l
l
a
t
i
o
n

Hy
d
r
a
u
l
i
c

T
e
s
t
i
n
g
Gr
o
u
n
d
w
a
t
e
r

S
a
m
p
l
i
n
g
Va
p
o
r

S
a
m
p
l
i
n
g
Su
r
f
a
c
e

G
e
o
p
h
y
s
i
c
s
10. Groundwater Transport N N N N N N N N N N N 
Use groundwater chemistry and hydraulic data to
evaluate potential flow paths and model the attenuation
of the constituent of concern.
11. Receptors N N N N N N N N N N N 
Review municipal water connections and water supply
well permits within 1,500 feet of the site. Sample surface
water and nearby domestic wells.
Notes
Y: Yes - geoprobe or hand auger advanced to depth below waste or no waste detected in borings
N: No - has not been investigated
P: Partial - has been partially investigated, or the nature of the slope defines an obvious side to the pit, or area has a well defined berm but has not been investigated.
A receptor survey needs to be performed to determine the proximity of
potential receptors such as surface water bodies and private water
supply wells. If receptors are identified within 1,500 feet of the SDUs
then they should be sampled.
Needs to be evaluated. Without hydraulic data and an adequate
performance monitoring network of wells, the evaluation of
groundwater transport cannot be performed. Groundwater transport
provides and understanding of the direction and velocity of
groundwater flow in the aquifer system. Understanding these
parameters supports remedial design and modeling efforts.
Surface Disposal Unit – Permit WQ0003698
City of Marion
Page 2 of 2
April 2023
Table 2
List of Analytes for Groundwater and Soil/Biosolids
Analysis Medium
Permit-Required
Analyte Method
Groundwater Surface Water Supply Well
Volatile Organic Compound Water Yes EPA 8260 - Low Concentration X X X
Total Metals Water Yes EPA 6010/200.7 (ICP)X X X
Sulfide Water No SM 4500-S2D X X —
Sulfate Water No EPA 300.0 X X —
Alkalinity Water No SM 2320B X X —
Biochemical Oxygen Demand Water No SM 5210B X X —
Chemical Oxygen Demand Water No SM 5220D X X —
Chloride Water No EPA 300.0 X X —
Nitrogen, Ammonia Total (as N)Water Yes EPA 350.1 X X X
Nitrogen, Nitrate Total (as N)Water Yes EPA 353.2 X X X
Nitrogen, Nitrite Total (as N)Water Yes EPA 353.2 X X X
Nitrogen, Total Kjeldahl Nitrogen (as N)Water Yes EPA 351.2 X X X
Total Organic Carbon Water No SM 5310C X X —
Ortho Phosphate as P Water Yes EPA 300.0 X X X
Soil/Biosolids Waste Soil
Biosolid
Waste WDA Waste
Volatile Organic Compound Soil Yes EPA 8260 - Low Concentration X X X
Total Metals Soil Yes EPA 6010C X X X
Chloride Soil No EPA 9056A X X X
Nitrogen, Ammonia Total (as N)Soil Yes EPA 350.1 X X X
Nitrogen, Nitrate Total (as N)Soil Yes EPA 353.2 X X X
Nitrogen, Nitrite Total (as N)Soil Yes EPA 353.2 X X X
Nitrogen, Total Kjeldahl Nitrogen (as N)Soil Yes EPA 351.2 X X X
Notes:
—: not applicable
WDA: Pre-1981 Waste Disposal Area
Groundwater/Surface Water
Sample Type
Metals to include (underline indicates required by permit): Arsenic, barium, boron, cadmium, calcium, chromium, cobalt, iron, lead, magnesium, manganese, sodium, mercury, nickel, potassium, and zinc.
Permit Required Analyte: The analytes listed as permit required are part of the compliance monitoring program required by Permit No. WQ0003698. The remaining analytes are for aquifer characteriazation and will used along
with the permit required analytes to perform modeling or prediticitive calculations to support evaluation of remedial options.
Surface Disposal Unit – Permit WQ0003698
City of Marion
Page 1 of 1
April 2023
Table 3
Implementation Schedule
Phase Description Scope of Work and Schedule Range of Estimated Cost
July 2023
to
June 2024
July 2024
to
June 2025
July 2025
to
June 2026
July 2026
to
June 2027
July 2027
to
June 2028
Surface Water Assessment and Sampling
Domestic Well Sampling
Revise Conceptual Site Model & Reporting
Initial Land Clearing
Surface Geophysics
SDU Soil/Biosolid Waste Borings: Waste, Soil and Groundwater Sampling
Target SDU Locations: Pit A-1, A-2, B, & C and Pre-1981 Disposal Area
Revise Conceptual Site Model & Reporting
SDU Soil/Biosolid Waste Borings: Waste, Soil and Groundwater Sampling
Target SDU Loctions: Pit D, E, F-1, F-2, G-1, G-2, G-3, H
Revise Conceptual Site Model & Reporting
Potential Monitoring Well Installation and Groundwater Sampling
Hydraulic Testing and Analysis
Revise Conceptual Site Model
Groundwater Transport Modeling/Predictive Calculations
Establish Compliance Boundary and Update Site Map
Finalize compliance monitoring plan
Survey
Design Final Cover and Stormwater Management Design
$37,870 to $47,340
To be determined
To be determined
2
1
Initial Land Clearing & Surface
Geophysics
Risk-Based Assessment
Preliminary SDU Assessment
Additional Assessment Work and
Remaining Requirments5
Remaining SDU Assessment4
3
$18,120 to $22,650
$30,000 to $37,500
Surface Disposal Unit – Permit WQ0003698
City of Marion
Page 1 of 1
April 2023

Attachment A
Permit No. WQ0003698
July 18, 2022
J.ROBERT BOYETTE – CITY MANAGER
CITY OF MARION
POST OFFICE DRAWER 700
MARION, NORTH CAROLINA 28752
Subject: Permit No. WQ0003698
Corpening Creek SDU
Surface Disposal of Residuals
McDowell County
Dear Mr. Boyette:
In accordance with your permit renewal request received January 10, 2022, and subsequent
additional information received April 21, 2022, we are forwarding herewith Permit No. WQ0003698 dated
July 18, 2022, to the City of Marion for the continued operation of the subject residuals management
program. Please note that this renewed permit shall become effective on August 1, 2022 (i.e., the day after
the expiration date of the existing permit).
This permit shall be effective from August 1, 2022 through January 31, 2029, shall replace Permit
No. WQ0003698 issued June 8, 2017, and shall be subject to the conditions and limitations as specified
therein. The Permittee shall submit a renewal application no later than August 4, 2028.
Please pay particular attention to the monitoring requirements listed in Attachment C for they may
differ from the previous permit issuance. Failure to establish an adequate system for collecting and
maintaining the required operational information shall result in future compliance problems.
Please note that on September 1, 2018, North Carolina Administrative Code Title 15A Subchapter
02T – Waste not Discharged to Surface Waters was readopted. Accordingly, this permit incorporates the
requirements of these rules, therefore, please take the time to review this permit thoroughly.
The Division has removed the following permit conditions since the last permit issuance dated
June 8, 2017:
➢Old Condition IV.2. – This condition has been removed because there are no residuals being
disposed.
➢Old Condition VI.2. – This condition has been removed because the permit is not voidable.
Mr. J. Robert Boyette
July 18, 2022
Page 2 of 3
The following permit conditions are new since the last permit issuance dated June 8, 2017:
➢ Condition I.1. – The Permittee shall submit a scope of work and timetable to complete the site
assessment required in Condition I.2.
➢ Condition I.2. – The Permittee shall submit a site assessment to delineate the extent of the
surface disposal units.
➢ Condition I.3. - The Permittee shall submit a final cover plan for all surface disposal units.
➢ Condition I.4. – The Permittee shall evaluate the groundwater monitoring plan based on the
results of the site assessment.
➢ Condition I.5. – The Permittee shall submit a permit modification to incorporate the
information about the surface disposal units from the site assessment and the new groundwater
monitoring information plan.
➢ Condition II.5. – This condition updates the setbacks to the first time each surface disposal unit
was referenced.
➢ Condition V.2. – The Permittee shall inspect the residuals and surface disposal facilities to
prevent malfunctions, facility deterioration, and operator errors that may result in discharges
of wastes to the environment, threats to human health, or public nuisance.
➢ Condition VI.3. – Unless specifically requested and approved in this permit, there are no
variances to administrative codes or general statutes governing the construction or operation of
the facilities permitted herein.
➢ Condition VI.6. – The Permittee shall retain a set of Division-approved plans and specifications
for the life of the facilities permitted herein.
➢ Condition VI.7. – The Permittee shall maintain this permit until the proper closure of all
facilities permitted herein, or until the facilities permitted herein are permitted by another
authority.
➢ Condition VI.10. – This permit shall not be renewed if the Permittee or any affiliation has not
paid the required annual fee.
➢ An Attachment B has been added to account for existing surface disposal units.
➢ Attachment C – The parameters of Boron, Barium, Cobalt, Total Kjeldahl Nitrogen, Nitrite and
Orthophosphate have been added to the groundwater sampling schedule. The parameters of
Arsenic, Chloride, Lead, Phenolics, Total Dissolved Solids, Total Organic Carbon, and Total
Suspended Solids have been removed. The sampling frequency has been increased from Semi-
Annually to 3 x Year.
If any parts, requirements, or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall be in the form 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, NC 27699-6714. Otherwise, this permit shall be final and binding.
Mr. J. Robert Boyette
July 18, 2022
Page 3 of 3
If you need additional information concerning this permit, please contact Erick Saunders at (919)
707-3659 or [e-mail].
Sincerely,
Richard E. Rogers, Jr., Director
Division of Water Resources
cc: McDowell County Health Department (Electronic Copy)
Asheville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Laserfiche File (Electronic Copy)
Digital Permit Archive (Electronic Copy)

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WQ0003698 Version 5.0 Shell Version 200201 Page 1 of 10
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH
SURFACE DISPOSAL OF RESIDUALS 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 operation of a post closure care program for the City of Marion’s surface disposal units consisting
of an estimated 11 surface disposal units (SDUs) listed in Attachment B which have been inactive since
2001 (i.e., no longer permitted to receive residuals) and closed since 2002. All residuals disposed in the
surface disposal units were generated by the City of Marion’s Corpening Creek WWTP (Permit No.
NC0031879) and Catawba River WWTP (Permit No. NC0071200).
The post closure care activities associated with the surface disposal units shall not result in discharge of
wastes to surface waters, pursuant to the application received January 10, 2022, subsequent additional
information received April 21, 2022, and in conformity with other supporting data subsequently filed and
approved by the Department of Environmental Quality and considered a part of this permit. The disposal
of residuals is regulated under Title 40 Code of Federal Regulations Part 503. This permit does not exempt
the Permittee from complying with Federal Regulation 40 CFR Part 503.
This permit shall be effective from August 1, 2022 through January 31, 2029, shall replace Permit No.
WQ0003698 issued June 8, 2017, and shall be subject to the following conditions and limitations:

WQ0003698 Version 5.0 Shell Version 200201 Page 2 of 10
I. SCHEDULES
1. Prior to January 28, 2023, the Permittee shall submit a scope of work detailing the actions to be taken
to complete the site assessment in Condition I.2. This scope of work document shall include a projected
timeline to complete these tasks. This documentation shall be sent to the Division of Water Resources,
Non-Discharge Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617, or Non-
[e-mail]. [15A NCAC 02T .0108(b)(1)(B)]
2. Prior to August 1, 2024, the Permittee shall complete a site assessment to determine the extent of the
waste boundaries associated with the surface disposal of residuals activities covered under this permit.
This site assessment shall include the following:
a. A survey of the site depicting the horizontal and vertical delineation of the waste boundaries for all
SDUs on site. This survey shall be recorded in the McDowell County Register of Deeds;
b. A delineation of the compliance and review boundaries for these waste boundaries in accordance
with 15A NCAC 02L .0107, 02L .0108, and Conditions II.6. and II.7.;
c. The condition/depth of the cover material for each SDU;
d. The vertical separations between the bottoms of the SDUs and the seasonal high water table
(SHWT);
e. The approximate volumes of residuals contained in each SDU; and
f. Documentation of any solid waste material in the vicinity of the SDUs that does not originate from
the activities covered in this permit, and an identification of where this material was found.
Work that is within the scope of the practice of geology and engineering, which involves site
assessment, the interpretation of subsurface geologic conditions, or any work requiring detailed
technical knowledge of site conditions shall be performed by persons, firms or professional
corporations who are duly licensed to offer geological or engineering services. This site assessment
and supporting documentation shall be sent to the Division of Water Resources, Non-Discharge Branch,
1617 Mail Service Center, Raleigh, NC 27699-1617, or [e-mail]. [15A
NCAC 02T .0108(b)(1)(B)]
3. Within 180 days of the completion of the site assessment required in Condition I.2., the Permittee shall
submit a final cover plan for the surface disposal units. This shall include the reestablishment of a final
cover to limit infiltration into the unit and promote positive drainage away from the units. This final
cover shall have a protective vegetative cover free of woody vegetation in accordance with Condition
III.6. of the permit to be accessible for inspection and maintenance. [15A NCAC 02T .0108(b)(1)(A)]

WQ0003698 Version 5.0 Shell Version 200201 Page 3 of 10
4.Within 30 days following the completion of the site assessment as required in Condition I.2., the
Permittee shall submit a groundwater monitoring plan to the Asheville Regional Office for review to
assess the full extent of the groundwater monitoring exceedances as detailed in the March 3, 2022
Notice of Violation NOV-2022-LV-0130. This plan shall evaluate the existing monitoring wells in
relation to the compliance and boundaries determined by the site investigation to evaluate if corrective
action is required in accordance with 15A NCAC 02L .0106 and include proposals for new groundwater
monitoring wells to determine the source and extent of the contamination. This plan shall include one
digital copy of a site map with a scale no greater than 1-inch equals 100 feet; however, special
provisions may be granted upon prior approval for large properties. The map shall include the following
information:
a.Legend, north arrow, scale, and legible in black and white.
b.Topographic contour intervals not exceeding 10 feet or 25 percent of total site relief.
c.All habitable residences or places of assembly within 500 feet of the surface disposal site.
d.Location of all wells, streams (ephemeral, intermittent, and perennial), springs, lakes, ponds,
ditches, and other surface drainage features within 500 feet of the surface disposal site.
e.Location and identification of each monitoring well (identify any background/upgradient wells).
f.Latitude and longitude coordinates of each monitoring wells (decimal degrees to the sixth decimal
degree and in NAD83).
g.Location and identification of major components of the waste disposal system.
h.The perimeter of all surface disposal sites with site names (named according to the approved
permit)
i.Location and ownership of property boundaries within 500 feet of the surface disposal site
(including road/rail rights-of-way and easements).
j.Latitude and longitude of the established horizontal control monument (decimal degrees to the sixth
decimal degree).
k.Elevation of the top of the well casing (i.e., measuring point) relative to a common datum.
l.Depth of water below the measuring point at the time the measuring point is established.
m.Delineation of the compliance and review boundaries.
n.Distance measurements verifying all setbacks are being met.
o.Stormwater drainage controls.
p.100-year floodplain.
q.The date the map is prepared and/or revised.
Boundaries and physical features not under purview of other licensed professions shall be provided by
a Professional Surveyor. Control monuments shall be installed in such a manner and made of such
materials that the monument will not be destroyed due to activities taking place on the property. The
map and any supporting documentation shall be sent to the Division of Water Resources , Non-
Discharge Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617, or Non-
[e-mail]. [15A NCAC 02C .0105(f), 02L .0106, 02T .0108(b)(1)(B)]
5.Following the completion of the site assessment required in Condition I.2. and the groundwater
monitoring plan as required in Condition I.4., this permit shall be modified to include the names and
locations of the SDUs in Attachment B and new groundwater monitoring wells in Attachment C. [15A
NCAC 02T .0108(b)(1)(A)]
6.The Permittee shall request renewal of this permit on Division-approved forms no later than August 4,
2028. [15A NCAC 02T .0105(b), 02T .0109]
WQ0003698 Version 5.0 Shell Version 200201 Page 4 of 10
II.PERFORMANCE STANDARDS
1.The Permittee shall maintain and operate the subject residuals management program so there is no
discharge to surface waters, nor any contravention of groundwater or surface water standards. In the
event the residuals management program fails to perform satisfactorily, including the creation of
nuisance conditions due to improper operation and maintenance, the Permittee shall take immediate
corrective actions and contact the Asheville Regional Office supervisor. [15A NCAC 02T
.0108(b)(1)(A)]
2.This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface
water resulting from the operation of this residuals management program. [15A NCAC 02T
.0108(b)(1)(A)]
3.Groundwater monitoring wells shall be constructed in accordance with 15A NCAC 02C .0108
(Standards of Construction for Wells Other than Water Supply), and any other jurisdictional laws and
regulations pertaining to well construction. [15A NCAC 02C .0108]
4.No residuals shall be approved for surface disposal in the surface disposal units. [15A NCAC 02T
.0108(b)(1)(A)]
5.The facilities herein were permitted per the following setbacks:
a.Surface disposal sites 1 through 11 were originally permitted January 10, 2001. The setbacks for
surface disposal sites originally permitted or modified from February 1, 1993 to August 31, 2006
are as follows (all distances in feet):
i.Each habitable residence or place of assembly under separate ownership:400 1
ii.Each private or public water supply source:100
iii.Surface waters:100
iv.Groundwater lowering ditches:25
v.Surface water diversions (upslope):10
vi.Surface water diversions (downslope):25
vii.Each well with exception of monitoring wells:100
viii.Each property line:50 2
ix.Top of slope of embankments or cuts of two feet or more in vertical height:15
x.Each water line:10
xi.Each swimming pool:100
xii.Public right of way:50
xiii.Nitrification field:20
xiv.Each building foundation or basement:15
1 Habitable residences or places of assembly under separate ownership constructed after the
facilities herein were originally permitted or subsequently modified are exempt from this
setback.
2 Setbacks to property lines are not applicable when the Permittee, or the entity from which the
Permittee is leasing, owns both parcels separated by the property line.
[15A NCAC 02H .0219(j)(5)]

WQ0003698 Version 5.0 Shell Version 200201 Page 5 of 10
b. Any previously unknown surface disposal units discovered in the site assessment as required by
Condition I.2. shall meet the most current setbacks. The setbacks for surface disposal sites
originally permitted or modified on or after September 1, 2018 are as follows (all distances in feet):
i. Each habitable residence or place of assembly under separate ownership: 400 1
ii. Each private or public water supply source: 100
iii. Surface waters: 100
iv. Groundwater lowering ditches: 100
v. Surface water diversions: 25
vi. Each well with exception of monitoring wells: 100
vii. Each property line: 50 2
viii. Each water line: 10
ix. Subsurface groundwater lowering drainage systems: 100
x. Public right of way: 50
1 Habitable residences or places of assembly under separate ownership constructed after the
facilities herein were originally permitted or subsequently modified are exempt from this
setback.
2 Setbacks to property lines are not applicable when the Permittee, or the entity from which the
Permittee is leasing, owns both parcels separated by the property line.
[15A NCAC 02T .1108(d), 02T .1108(f), 02T .1108(g)]
6. Surface disposal sites permitted on or after December 30, 1983 have a compliance boundary that is
either 250 feet from the surface disposal area, or 50 feet within the property boundary, whichever is
closest to the surface disposal area. Any exceedance of groundwater standards at or beyond the
compliance boundary shall require corrective action. Division-approved relocation of the compliance
boundary shall be noted in Attachment B. Multiple contiguous properties under common ownership
and permitted for use as a disposal system shall be treated as a single property with regard to
determination of a compliance boundary. [15A NCAC 02L .0106(d)(2), 02L .0107(b), 02T .0105(h),
G.S. 143-215.1(i), G.S. 143-215.1(k)]
7. The review boundary is midway between the compliance boundary and the surface disposal area. Any
exceedance of groundwater standards at or beyond the review boundary shall require preventative
action. [15A NCAC 02L .0106(d)(1), 02L .0108]
8. No wells, excluding Division-approved monitoring wells, shall be constructed within the compliance
boundary except as provided for in 15A NCAC 02L .0107(g). [15A NCAC 02L .0107]

WQ0003698 Version 5.0 Shell Version 200201 Page 6 of 10
III. OPERATION AND MAINTENANCE REQUIREMENTS
1. The Permittee shall operate and maintain the residuals management program as a non-discharge system.
[15A NCAC 02T .1100]
2. The Permittee shall maintain a Division-approved Operation and Maintenance Plan that shall include:
a. Description of the program, and associated facilities and equipment, in sufficient detail to show
what operations are necessary for the program to function and by whom the functions are to be
conducted;
b. Description of anticipated maintenance of facilities and equipment associated with the program;
c. Include provisions for safety measures, including restriction of access to sites and equipment;
d. Spill control provisions:
i. Response to upsets and bypasses including control, containment, and remediation; and
ii. Contact information for plant personnel, emergency responders, and regulatory agencies;
e. Detailed sampling and monitoring procedures:
i. Names or titles of personnel responsible for conducting sampling and monitoring;
ii. Description of monitoring procedures including parameters to be monitored; and
iii. Sampling frequency and procedures to assure that representative samples are collected.
Fluctuation in temperature, flow, and other operating conditions can affect the quality of the
residuals gathered during a particular sampling event. The sampling plan shall account for any
foreseen fluctuations in residuals quality and indicate the most limiting times for residuals to
meet pathogen and vector attraction reduction requirements.
f. Detailed procedures for post-closure care management.
[15A NCAC 02T .1110(a)]
3. Appropriate measures shall be taken to control public access to the surface disposal unit for the 36-
month period following closure of the surface disposal unit. Such controls may include fencing and
the posting of signs indicating the activities conducted at each site. Ninety days before public access
to area greenways is to be allowed, the Permittee shall inform the Asheville Regional Office of its
intention to allow public access. [15A NCAC 02T .1109(d)(2)(G)]
4. Adequate provisions shall be taken to prevent surface runoff from any surface disposal unit. If runoff
cannot be prevented, a collection system shall be installed with the capacity to handle runoff from a 24 -
hour, 25-year storm event. All collected runoff shall be disposed in a Division approved manner. [15A
NCAC 02T .1109(d)(2)(D]
5. Measures shall be taken to prevent wind erosion from residual surface disposal sites. [15A NCAC 02T
.0108(b)(1)(A)]
6. A protective vegetative cover shall be established and maintained on all berms, pipe runs, erosion
control areas, surface water diversions, and earthen embankments (i.e., outside toe of embankment to
maximum allowable temporary storage elevation on the inside of the embankment). Trees, shrubs, and
other woody vegetation shall not be allowed to grow on the earthen dikes or embankments. Earthen
embankments shall be kept mowed or otherwise controlled and accessible. [15A NCAC 02T
.0108(b)(1)(A)]
7. A copy of this permit, as well as the post-closure care plan, shall be maintained on site during the life
of this permit. [15A NCAC 02T .0108(b)(1)]

WQ0003698 Version 5.0 Shell Version 200201 Page 7 of 10
IV. MONITORING AND REPORTING REQUIREMENTS
1. The Permittee shall conduct and report any Division required monitoring necessary to evaluate this
program’s impact on groundwater and surface water. [15A NCAC 02T .0108(c)]
2. Monitoring wells MW-1, MW-2, MW-3, and MW-4 shall be sampled at the frequencies and for the
parameters specified in Attachment C. All mapping, well construction forms, well abandonment forms
and monitoring data shall refer to the permit number and the well nomenclature as provided in
Attachment C and Figure X. [15A NCAC 02T .0105(m)]
3. Two copies of the monitoring well sampling and analysis results shall be submitted on a Compliance
Monitoring Form (GW-59), along with attached copies of laboratory analyses, on or before the last
working day of the month following the sampling month. The Compliance Monitoring Form (GW-59)
shall include this permit number, the appropriate well identification number, and one GW-59a
certification form shall be submitted with each set of sampling results. All information shall be
submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[15A NCAC 02T .0105(m)]
4. The methane gas concentration in the air at the surface disposal unit boundary shall be monitored semi-
annually. The methane gas concentration shall not exceed the Lower Explosive Limit (LEL). The
Division reserves the right to require continuous methane monitoring in accordance with established
policy should semi-annual monitoring indicate that the surface disposal unit is producing significant
volumes of methane gas that may endanger public health and safety. [15A NCAC 02T .0108(c), 02T
.1109(d)(2)(F)]
5. One hard copy and one electronic copy of an annual report shall be submitted on or before March 1st.
The annual report shall meet the requirements described in the Instructions for Residuals Application
Annual Reporting Forms. Instructions for reporting and annual report forms are available at
http://deq.nc.gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/non-
discharge-permitting-unit/reporting-forms, or can be obtained by contacting the Non-Discharge Branch
directly. The annual report shall be submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[15A NCAC 02T .1111(d)]

WQ0003698 Version 5.0 Shell Version 200201 Page 8 of 10
6. Noncompliance Notification
The Permittee shall report to the Asheville Regional Office, telephone number [phone], within
24 hours of first knowledge of the:
a. Any process unit failure (e.g., mechanical, electrical, etc.) rendering the facility incapable of
adequate residual treatment.
b. Any failure resulting in a discharge to surface waters.
c. Any time self-monitoring indicates the program has gone out of compliance with its permit
limitations.
d. Surface disposal of residuals abnormal in quantity or characteristic.
e. Any discharge from a vehicle or piping system transporting residuals.
Emergencies requiring reporting outside normal business hours shall call the Division’s Emergency
Response personnel at telephone number [phone], [phone], or [phone]. All
noncompliance notifications shall file a written report to the REGION Regional Office within five days
of first knowledge of the occurrence, and this report shall outline the actions proposed or taken to ensure
the problem does not recur. [15A NCAC 02T .0108(b)(1)(A)]
V. INSPECTIONS
1. The Permittee shall perform inspections and maintenance to ensure proper operation of the storage and
surface disposal facilities. [15A NCAC 02T .1110(f)]
2. The Permittee shall inspect the residuals and surface disposal facilities to prevent malfunctions, facility
deterioration, and operator errors that may result in discharges of wastes to the environment, threats to
human health, or public nuisances. The Permittee shall maintain an inspection log that includes the
date and time of inspection, observations made, and maintenance, repairs, or corrective actions taken.
The Permittee shall maintain this inspection log for a period of five years from the date of inspection,
and this log shall be made available to the Division upon request. [15A NCAC 02T .0108(b)(1)(A),
02T .1110(f)]
3. Division authorized representatives may, upon presentation of credentials, enter and inspect any
property, premises, or place related to the surface disposal sites or facilities permitted herein at any
reasonable time for determining compliance with this permit. Division authorized representatives may
inspect or copy records maintained under the terms and conditions of this permit, and may collect
groundwater, surface water, or leachate samples. [G.S. 143-215.3(a)(2)]

WQ0003698 Version 5.0 Shell Version 200201 Page 9 of 10
VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to a
Division enforcement action. [G.S. 143-215.6A, 143-215.6B, 143-215.6C]
2. This permit is effective only with respect to the nature and volume of wastes described in the permit
application, and Division-approved plans and specifications. [G.S. 143-215.1(d)]
3. Unless specifically requested and approved in this permit, there are no variances to administrative codes
or general statutes governing the construction or operation of the facilities permitted herein. [15A
NCAC 02T .0105(n)]
4. The issuance of this permit does not exempt the Permittee from complying with all statutes, rules,
regulations, or ordinances that other jurisdictional government agencies (e.g., local, state, and federal)
may require. [15A NCAC 02T .0105(c)(6)]
5. If the permitted residuals program change ownership, or the Permittee changes their name, the
Permittee shall submit a permit modification request on Division-approved forms. The Permittee shall
comply with all terms and conditions of this permit until the permit is transferred to the successor -
owner. [G.S. 143-215.1(d3)]
6. The Permittee shall retain a set of Division-approved plans and specifications for the life of the facilities
permitted herein. [15A NCAC 02T .0105(o)]
7. The Permittee shall maintain this permit until the proper closure of all facilities permitted herein, or
until the facilities permitted herein are permitted by another authority. [15A NCAC 02T .0105(j)]
8. This permit is subject to revocation or modification upon 60-day notice from the Division Director, in
whole or part for:
a. violation of any terms or conditions of this permit or Administrative Code Title 15A Subchapter
02T;
b. obtaining a permit by misrepresentation or failure to disclose all relevant facts;
c. the Permittee’s refusal to allow authorized Department employees upon presentation of credentials:
i. to enter the Permittee’s premises where a system is located or where any records are required
to be kept;
ii. to have access to any permit required documents and records;
iii. to inspect any monitoring equipment or method as required in this permit; or
iv. to sample any pollutants;
d. the Permittee’s failure to pay the annual fee for administering and compliance monitoring; or
e. a Division determination that the conditions of this permit are in conflict with North Carolina
Administrative Code or General Statutes.
[15A NCAC 02T .0110]

WQ0003698 Version 5.0 Shell Version 200201 Page 10 of 10
9. Unless the Division Director grants a variance, expansion of the facilities permitted herein shall not
occur if any of the following apply:
a. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has been convicted of
environmental crimes under G.S. 143-215.6B, or under Federal law that would otherwise be
prosecuted under G.S. 143-215.6B, and all appeals of this conviction have been abandoned or
exhausted.
b. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has previously abandoned
a wastewater treatment facility without properly closing the facility.
c. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid a civil
penalty, and all appeals of this penalty have been abandoned or exhausted.
d. The Permittee or any parent, subsidiary, or other affiliate of the Permittee is currently not compliant
with any compliance schedule in a permit, settlement agreement, or order.
e. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid an annual
fee.
[15A NCAC 02T .0120(b), 02T .0120(d)]
10. This permit shall not be renewed if the Permittee or any affiliation has not paid the required annual fee.
[15A NCAC 02T .0120(c)]
Permit issued this the 18th day of July 2022
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
____________________________________________
Richard E. Rogers, Jr., Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0003698
ATTACHMENT B – APPROVED SURFACE DISPOSAL SITES Certification Date: July 18, 2022
City of Marion Permit Number: WQ0003698 Version: 5.0
WQ0003698 Version 5.0 Attachment B Page 1 of 1
Field Owner Lessee County Latitude Longitude Net
Acreage Dominant Soil Series Footnotes
1 City of Marion McDowell TBD TBD TBD 1
2 City of Marion McDowell TBD TBD TBD 1
3 City of Marion McDowell TBD TBD TBD 1
4 City of Marion McDowell TBD TBD TBD 1
5 City of Marion McDowell TBD TBD TBD 1
6 City of Marion McDowell TBD TBD TBD 1
7 City of Marion McDowell TBD TBD TBD 1
8 City of Marion McDowell TBD TBD TBD 1
9 City of Marion McDowell TBD TBD TBD 1
10 City of Marion McDowell TBD TBD TBD 1
11 City of Marion McDowell TBD TBD TBD 1
Total
1. The location and size of each surface disposal unit shall be determined in the site assessment required by Condition I.2. and included into the permit a required by Condition I.5.

THIS PAGE BLANK
ATTACHMENT C – Groundwater Monitoring and Limitations Permit Number: WQ0003698 Version: 5.0
Monitoring Wells: MW-1R, MW-2, MW-3 and MW-4 6
WQ0003698 Version 5.0 Attachment C Page 1 of 2
GROUNDWATER CHARACTERISTICS GROUNDWATER STANDARDS MONITORING REQUIREMENTS
PCS Code Parameter Description Daily Maximum Frequency Measurement Sample Type Footnotes
01007 Barium, Total (as Ba) 700 µg/L 3 x Year Grab 1
01022 Boron, Total (as B) 700 µg/L 3 x Year Grab 1
01027 Cadmium, Total (as Cd) 2 µg/L 3 x Year Grab 1
01037 Cobalt, Total (as Co) 1 µg/L 3 x Year Grab 1
01045 Iron, Total (as Fe) 300 µg/L 3 x Year Grab 1
01055 Manganese, Total (as Mn) 50 µg/L 3 x Year Grab 1
00610 Nitrogen, Ammonia Total (as N) 1.5 mg/L 3 x Year Grab 1
00625 Nitrogen, Kjeldahl, Total (as N) mg/L 3 x Year Grab 1
00620 Nitrogen, Nitrate Total (as N) 10 mg/L 3 x Year Grab 1
00615 Nitrogen, Nitrite total (as N) 1 mg/L 3 x Year Grab 1
50786 Orthophosphate As P, Water mg/L 3 x Year Grab 1
00400 pH 6.5-8.5 mg/L 3 x Year Grab 1
GWVOC Volatile Compounds (GC/MS) Present: Yes/No Annually Grab 1, 4, 5
82546 Water level, distance from measuring point feet 3 x Year Calculated 1, 2, 3
1. 3 x Year sampling shall be conducted in March, July, and November; Annual sampling shall be conducted in November.
2. The measurement of water levels shall be made prior to purging the wells. The depth to water in each well shall be measured from the surveyed point on the top of the casing. The measurement
of pH shall be made after purging and prior to sampling for the remaining parameters.
3. The measuring points (top of well casing) of all monitoring wells shall be surveyed to provide the relative elevation of the measuring point for each monitoring well. The measuring points (top of
casing) of all monitoring wells shall be surveyed relative to a common datum.

ATTACHMENT C – Groundwater Monitoring and Limitations Permit Number: WQ0003698 Version: 5.0
Monitoring Wells: MW-1R, MW-2, MW-3 and MW-4 6
WQ0003698 Version 5.0 Attachment C Page 2 of 2
4. Volatile Organic Compounds (VOC) - In November only, analyze by one of the following methods:
a. Standard Method 6230D, PQL at 0.5 μg/L or less
b. Standard Method 6210D, PQL at 0.5 μg/L or less
c. EPA Method 8021, Low Concentration, PQL at 0.5 μg/L or less
d. EPA Method 8260, Low Concentration, PQL at 0.5 μg/L or less
e. Another method with prior approval by the Water Quality Permitting Section Chief
Any method used shall meet the following qualifications:
a. A laboratory shall be DWR certified to run any method used.
b. The method used shall include all the constituents listed in Table VIII of Standard Method 6230D.
c. The method used shall provide a PQL of 0.5 μg/L or less that shall be supported by laboratory proficiency studies as required by the DWR Laboratory Certification Unit. Any constituents
detected above the MDL but below the PQL of 0.5 μg/L shall be qualified (estimated) and reported.
5. If any volatile organic compounds (VOC) are detected as a result of monitoring as provided in Attachment C, then the Asheville Regional Office supervisor, telephone number [phone],
shall be contacted immediately for further instructions regarding any additional follow-up analyses required.
6. Monitoring wells shall be reported consistent with the nomenclature and location information provided in this attachment.
Monitoring Well Latitude Longitude
MW-1R 35.652195º -81.965092º
MW-2 35.651648º -81.960437º
MW-3 35.650128º -81.960112º
MW-4 35.652602º -81.962813º

Attachment B
Notice of Violation and Intent to Enforce,
NOV-2022-LV-0130

March 3, 2022

CERTIFIED MAIL #7021 2720 0000 1254 5196
RETURN RECEIPT REQUESTED

J. Robert Boyette, City Manager
City of Marion
P.O. Drawer 700
Marion, NC 28752 0700

Subject: NOTICE OF VIOLATION AND INTENT TO ENFORCE
NOV-2022-LV-0130
Title 15A NCAC Subchapter 2L
Groundwater Quality Violations
Permit No. WQ0003698
City of Marion - Corpening Creek Wastewater Treatment Plant
Class B Residuals Surface Disposal Units
McDowell County

Dear Mr. Boyette:

The following Notice of Violation is being submitted to you based upon on a review of the
November 2021 groundwater monitoring report (GW59). This letter is to formally notify you of
violations of 15A NCAC 2L (Groundwater Quality Standards) and to advise you of what you are
required to do to correct these violations.

The following 2L violations include, but are not limited to the following:

Well No.

Date

Constituent

Concentration

NC Standard
or IMAC*

Class
Micrograms per liter (µg/l)

MW-2

11/30/2021

Iron

28,400

300

GA
MW-2

11/30/2021

Manganese

1,080

50

GA
MW-2

11/30/2021

Ammonia

6,000

1,500

GA
MW-3

11/30/2021

Manganese

132

50

GA
DocuSign Envelope ID: 0D8438AC-2974-426E-A722-E11E09B1937D

J. Robert Boyette
March 3, 2022
Page 2 of 3

Well No.

Date

Constituent

Concentration

NC Standard
or IMAC*

Class
Micrograms per liter (µg/l)
MW-3 11/30/2021 Nitrate 12,100 10,000 GA
*IMAC- Interim Maximum Allowable Contaminant

The reported constituent concentrations exceed those standards for CLASS GA waters, established
in 15A NCAC 2L .0202. Due to these violations, you are required to take the following actions in
accordance with applicable provisions in 15A NCAC 2L .0106 (d):

(1) at or beyond a review boundary: the person shall demonstrate, through predictive
calculations or modeling, that natural site conditions, facility design and operational
controls will prevent a violation of standards at the compliance boundary. Alternately, the
person may submit a plan for alteration of existing site conditions, facility design, or
operational controls that will prevent a violation at the compliance boundary, and
implement that plan upon its approval by the Secretary.

(2) at or beyond a compliance boundary: the person shall respond in accordance with
Paragraph (f) of this Rule, assess the cause, significance and extent of the violation of
standards and submit the results of the investigation, and a plan and proposed schedule for
corrective action to the Secretary. The permittee shall implement the plan as approved by
and in accordance with a schedule established by the Secretary. In establishing a schedule,
the Secretary shall consider any schedule proposed by the permittee, the scope of the
project, the extent of contamination, and the corrective action being proposed.

Please note that the site assessment required by 15A NCAC 2L .0106(g), and conducted pursuant to
requirements of Paragraph (d) of this Rule, shall include the following:

1. The source and cause of contamination;

2. Any imminent hazards to public health and safety and actions taken to mitigate them in
accordance with Paragraph (f) of this Rule;

3. All receptors and significant exposure pathways;

4. The horizontal and vertical extent of soil and groundwater contamination and all
significant factors affecting contaminant transport; and

5. Geological and hydrogeological features influencing the movement, chemical, and
physical character of the contaminants.
DocuSign Envelope ID: 0D8438AC-2974-426E-A722-E11E09B1937D

J. Robert Boyette
March 3, 2022
Page 3 of 3

This Office requests that you provide a response to this letter in writing no later than sixty (60) days
after receipt of this Notice. Your response should be sent to the Asheville Regional Office at the
letterhead address. In your response, please confirm the City of Marion’s intent to comply with the
above requirements by specifying the actions you plan to undertake to correct the violations and by
submitting a proposed schedule for accomplishing these actions. Failure to submit the required
reports or failure to expeditiously eliminate the contaminant source and restore groundwater
quality in the affected area may result in the recommendation of enforcement action. Division of
Water Resources staff are available to discuss an assessment approach consisting of phases and
that focus on those constituents detected in the above-referenced monitoring wells. Please note
additional waste boundary assessments may be required as a condition in your WQ0003698 permit
currently under review for issuance.

Please note that assessment of civil penalties may have already been recommended for violations
described within this Notice of Violation. Failure to comply with the State's rules, in the manner and
time specified, may result in the assessment of additional civil penalties and/or the use of other
enforcement mechanisms available to the State.

Fines may be imposed under NCGS 143-215.6A(a)(1) of not more than $25,000 per violation of any
classification, standard, limitation or management practice established pursuant to G.S. 143-214.1.
Additional action may include the issuance of a special order against you under the authority of G.S.
143-215.2, or a request to the Attorney General to institute an action for injunctive relief. If any
failure to act is continuous, penalties may be assessed not to exceed a maximum penalty of $25,000
per day per violation under NCGS 143-215.6A(b) so long as the violation continues.

We appreciate your attention and prompt response in this matter. If you have questions, please do
not hesitate to call Brett Laverty at [phone] or [e-mail].

Sincerely,

G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ec: ARO files
Brant Sikes – City of Marion Public Works Department
DocuSign Envelope ID: 0D8438AC-2974-426E-A722-E11E09B1937D