WQ0019960_NOD-2024-PC-0155_20240822_CEI

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

August 22, 2024

J Robert Boyette, City Manager
City of Marion
Email: [e-mail]

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2024-PC-0155
Permit No. WQ0019960
City of Marion RLAP
Compliance Inspection Report
Annual Report Review 2023
McDowell County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the City of Marion RLAP on August
22, 2024. This inspection was conducted to verify that the facility is operating in compliance with the conditions
and limitations specified in Non-discharge Permit No. WQ0019960. A summary of the findings and comments
noted during the inspection are provided in the enclosed copy of the inspection report.

The Annual Report Review inspection was conducted by Division of Water Resources staff from the Asheville
Regional Office. The following deficiency was noted during the inspection:
Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________ Record Keeping ESP results were not provided in the SSFA results for fields F1 and F2 (permit condition IV.5). _________________________________________________________________________________________________________________________________________________________________________

Docusign Envelope ID: 50262AC5-4D2F-489B-84E4-F0FAEE27E644

Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. To prevent further action, carefully review these deficiencies and address the causes of
non-compliance to prevent the recurrence of similar situations.
If you should have any questions, please do not hesitate to contact Melanie Kemp with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4500 or [e-mail].

Sincerely,

Andrew Moore, Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Compliance Evaluation Inspection Report

Ec: LF, Tim Horton (WWTP ORC), Zach Key (US Biosolids)
Docusign Envelope ID: 50262AC5-4D2F-489B-84E4-F0FAEE27E644
Compliance Inspection Report
Permit:WQ0019960 Effective:08/12/21 Expiration:10/31/27 Owner :City of Marion
SOC:
Contact Person:
Region:
County:
Directions to Facility:
McDowell
Asheville
Brant Sikes
Effective:Expiration:Facility:City of Marion RLAP
3982 NC 226 S
Marion NC 28752
Title:Phone:[phone]
From ARO: I-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right.
Secondary ORC(s):
336-957-7871Phone:27660Certification:Zach D KeyPrimary ORC:
LA,System Classifications:
On-Site Representative(s):
Related Permits:
NC0031879 City of Marion - Corpening Creek WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
08/22/2024 10:00AM 01:00PM
Melanie Kemp
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Land Application of Residual Solids (503)
Annual Report Review
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Pathogen and Vector Attraction
(See attachment summary)
Page 1 of 4
Docusign Envelope ID: 50262AC5-4D2F-489B-84E4-F0FAEE27E644
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0019960
08/22/2024 Annual Report Review
City of Marion
Routine
Inspection Summary:
Melanie Kemp, with the Asheville Regional Office, completed the review of the Town of Marion’s 2023 RLAP Annual Report to
determine whether the facility processed and monitored all residuals in compliance with Permit No. WQ0019960.
The Town land applied approximately 143 dry tons of Class B residuals to 4 of the 6 permitted fields.
Pathogen Reduction (PR) is met through Fecal Coliform Density (Alternative 1). All samples were below limits.
Vector Attraction Reduction (VAR): The city meets VAR via SOUR and/or Alkaline Stabilization. All appropriate records were
provided.
Pollutants of Concern: The City’s residuals were all below ceiling concentration for pollutants of concern.
Metals & Nutrients: All metals and nutrient parameters for source residuals were analyzed per section IV.3 of the permit.
PAN and SAR are reported on the Annual Residual Sampling Summary Form - B. It should be noted that the results for
Calcium were reported incorrectly on form RSSF-B (result was 16,800 mg/kg, not 25.6 mg/kg).
Soil Fertility Analysis: ESP results were not provided for fields F1 and F2. ESPs for fields F3 and F4 were below 15. Lime
was applied to all the fields in use.
Non-hazardous waste characterization is required once per permit cycle and was sampled in February 2023.
The following deficiency was noted:
•ESP results were not provided in the SSFA results for fields F1 and F2 (permit condition IV.5).
Page 2 of 4
Docusign Envelope ID: 50262AC5-4D2F-489B-84E4-F0FAEE27E644
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0019960
08/22/2024 Annual Report Review
City of Marion
Routine
Type Yes No NA NE
Distribution and Marketing
Land Application
Record Keeping Yes No NA NE
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on-site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
Permitee used 4 of the 6 permitted fields in 2022. All fields are planted in fescue. Metals and
nutrient parameters for source residuals are within permitted limits. ESP values results not
reported for fields F1 and F2.
Comment:
Pathogen and Vector Attraction Yes No NA NE
a. Fecal coliform SM 9221 E (Class A or B)
Class A, all test must be <1000 MPN/dry gram
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
Fecal coliform SM 9222 D (Class B only)
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
b. pH records for alkaline stabilization (Class A)
c. pH records for alkaline stabilization (Class B)
Page 3 of 4
Docusign Envelope ID: 50262AC5-4D2F-489B-84E4-F0FAEE27E644
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0019960
08/22/2024 Annual Report Review
City of Marion
Routine
Temperature corrected
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench-top Aerobic/Anaerobic digestion results
Facility uses SOUR method for VAR (alt 4).Comment:
Treatment Yes No NA NE
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Comment:
Page 4 of 4
Docusign Envelope ID: 50262AC5-4D2F-489B-84E4-F0FAEE27E644
Annual Report Review Class B Land Application Permit No. WQ00_________
Reporting Period: ___________

Permit Details:

• Is 503 OR 257
• Maximum Dry Tons Per Year: ________
• Number of acres permitted: ________
• Number of fields in permit: ________
• Counties that land is permitted for: ________
• Monitoring Frequency for TCLP: _________
• Monitoring Frequency for Residuals Analysis: ________
• Monitoring Frequency for Pathogen & Vector Attraction Reduction: ________
• Groundwater monitoring: Yes No

1. Annual Land Application Certification Form
• Was a certification form submitted? Yes No
• Was land application conducted during the reported year? Yes No
• How many dry tons and dry tons per acre were applied? _____________________________________
• Were the applications within the permitted amount? Yes No
• Verify PAN if more than 10 tons/acre? Yes No
• Did it indicate compliance? Yes No
• Was it signed by the appropriate people? Yes No

2. Monitoring
• Were the analyses conducted at the required frequency? Yes No
• Was an analyses taken for each source that was land applied? Yes No
• Were the metals analyses reported on the Residual Sampling Summary Form? Yes No
• Were the results reported in mg/kg? Yes No
• Were the pH’s 6.0 or greater for each residual sample? Yes No
• Were the heavy metals within ceiling concentration permit limits? Yes No
o Were the lab analyses attached? Yes No
• Were all the required parameters tested? Yes No
• Was TCLP analysis conducted? Yes No
• Were the TLCP contaminants within regulatory limits? Yes No
• Was a corrosivity, ignitability, and reactivity analysis conducted? Yes No

3. Field Summary (Class B Supplemental Field Form)
• Were all land application events recorded on the FSF and MFLS forms? Yes No
• How many fields were applied on this year? ________
• Was a Field Summary Form submitted for each field? Yes No
• Was the Regional Office notified prior to each land application event? Yes No
• Were all the residuals applied to permitted land? Yes No
• Were all the residuals applied from permitted sources? Yes No
• Were the field loading rates for each metal and PAN calculated (year to date)? Yes No
• Were the cumulative pollutant loading rates calculated? Yes No
• Were the calculations correct? Yes No
• Were the PAN loading rates within permit limits? Yes No
• Were the heavy metal cumulative pollutant loading rates within permit limits? Yes No
• Were the residuals applied on a suitable crop? Yes No
• Were the applications conducted during the crop’s growing season? Yes No
• Were the Field Summary Forms complete? Yes No
• Was lime application on Field Summary Form? Yes No

19960
2023
290
56.9
6
McDowell
once per permit cycle
Annually
Annually
143.07
Comment: Calcium reported incorrectly (16,800 mg/kg, not 25.6). TCLP sampled 2/13/23.
4
Docusign Envelope ID: 50262AC5-4D2F-489B-84E4-F0FAEE27E644
4. Pathogen and Vector Attraction Reduction
• Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted? Yes No
• Did the form(s) indicate the period of coverage, the residual class, and the pathogen reduction
alternative and the vector attraction reduction option used? Yes No

Class B Pathogen Review

Alternative 1 – Fecal Coliform Density
· Was the sampling conducted at the required frequency? Yes No
· Were seven samples taken? Yes No
· Was the geometric mean calculated and done correctly? Yes No
· Did the results show compliance (less than either 2,000,000 MPN/gram of total solids or 2,000,000
Colony Forming Units/gram of total solids)? Yes No

Alternative 2 – Use of Process to Significantly Reduce Pathogens (one of five)
· Was the sampling conducted at the required frequency? Yes No

Aerobic Digestion
· Was it an aerobic process (Inspection)? Yes No
· Were logs submitted showing time and temperature? Yes No
· Were temperatures within range for complete time period? Yes No
· Was the time and temperature between 40 days at 20°C (68°F) and 60 days at 15°C (59°F)?
Yes No

Air Drying
· Were the residuals on sand beds or pave or unpaved basins for three months? Yes No
· Was the ambient temperature above 0°C (32°F) for two months? Yes No
· Were the residuals partially digested? Yes No
· Were residuals exposed to atmosphere during two months above 0°C (not snow covered)?
Yes No

Anaerobic Digestion
·Was it an anaerobic process (Inspection)? Yes No
·Were logs submitted showing time and temperature? Yes No
·Were temperatures within range for complete time period? Yes No
·Was the time and temperature between 15 days at 35°C (95°F) to 55°C (131°F) and 60 days at 20°C
(68°F)? Yes No

Composting (usually will be Class A when composting is used) Yes No
Was it a composting procedure (not natural decay under uncontrolled conditions)?
Yes No
Were logs submitted showing time and temperature? Yes No
See White House Manual for additional requirements.

Lime Stabilization
· Was alkaline material added to residuals a form of lime (hydrated lime, quicklime, lime containing kiln
dust or fly ash)? Yes No
· Were logs submitted showing time and temperature? Yes No
· Was the pH raised to 12 after two hours of contact? Yes No
· Were logs submitted showing time and pH? Yes No
· Was temperature corrected to 25°C (77°F) (by calculation, NOT auto correct)? Yes No

Alternative 3 – Use of Processes Equivalent to RSRP
(Not commonly use. See White House Manual page 100-103, tables 11-1 and 11-2.)

Docusign Envelope ID: 50262AC5-4D2F-489B-84E4-F0FAEE27E644
Class B Vector Attraction Reduction Review
· Was the sampling conducted at the required frequency? Yes No

Option 1 – 38% Volatile Solids Reduction
· Was there 38% reduction? Yes No
· Were lab sheets/calculations in report? Yes No
· Was the reduction on volatile solids (not total solids)? Yes No
· Were the samples taken at beginning of digestion process and before application (Inspection)?
Yes No
· Were calculations correct? Yes No

Option 2 – 40-Day Bench Scale Test
· Were residuals from anaerobically digested treatment (Inspection)? Yes No
· Was average temperature of the WWTP digester between 30°C (86°F) – 40°C (104°F)?
Yes No
· Were residuals anaerobically digested in lab? Yes No
· Was the test run for 40 days? Yes No
· Was the lab bench-scale test done between 30°C (86°F) and 37°C (99°F)? Yes No
· Was the reduction of on volatile solids (not total solids)? Yes No
· Was the reduction less than 17%? Yes No
· Were lab sheets/calculations in report? Yes No
· Were calculations correct? Yes No

Option 3 – 30-Day Bench Scale Test
· Were residuals from aerobically digested treatment (Inspection)? Yes No
· Were residuals aerobically digested in lab? Yes No
· Were residuals 2% or less total solids? Yes No
· If not 2% total solids, was the test ran on a sample diluted to 2% with unchlorinated effluent?
Yes No
· Was the test run for 30 days? Yes No
· Was the test done at 20°C (68°F)? Yes No
· Was the reduction of on volatile solids (not total solids)? Yes No
· Was the reduction less than 15%? Yes No
· Were lab sheets/calculations in report? Yes No
· Were calculations correct? Yes No

Option 4 – Specific Oxygen Uptake Rate (SOUR)
· Were residuals form aerobically digested treatment (Inspection)? Yes No
· Were residuals 2% or less total solids (dry weight basis) (not diluted)? Yes No
· Was the test done between 10°C (50°F) and 30°C (86°F)? Yes No
· Was the temperature corrected to 20°C (68°F)? Yes No
· Was the SOUR equal to or less than 1.5 mg of oxygen per hour per gram of total residual solids (dry
weight basis)? Yes No
· Was the sampling holding time two hours? Yes No
· Was the test started within 15 minutes of sampling or aeration maintained? Yes No

Option 5 – 14-Day Aerobic Process
· Were the residuals from aerobically digested treatment (Inspection)? Yes No
· Were the residuals treated for 14 days? Yes No
· Was the residuals temperature higher than 40°C (104°F) for a 14-day period? Yes No
· Was the average residuals temperature higher than 45°C (113°F)? Yes No

Docusign Envelope ID: 50262AC5-4D2F-489B-84E4-F0FAEE27E644
Option 6 – Alkaline Stabilization
· Was the pH of the residuals raised to 12 or higher by the addition of alkali? Yes No
· Did the pH of residuals remain at 12 or higher for two hours without the addition of more alkali?
Yes No
· Did the pH of residuals remain at 11.5 or higher for an additional twenty-two hours
(i.e. 24 hours total) without the addition of more alkali? Yes No
· Was the pH corrected to 25°C (77°F) (by calculation, NOT auto correct)? Yes No

Option 7 – Drying of Stabilized Residuals
· Does the residuals contain any unstabilized residuals? Yes No
· Were the residuals mixed with any other materials? Yes No
· Were the residuals dried up to 75% total solids? Yes No

Option 8 – Drying of Unstabilized Residuals
· Were the residuals mixed with any other materials? Yes No
· Were the residuals dried to 90% total solids? Yes No

Option 9/10 – Injection/Incorporation
· Was there any significant amount of residuals on land surface one hour after injection (Inspection)?
Yes No
· Was injection done on pasture or hay field? Yes No
· Was injection done at time that crop was growing? Yes No
· If Class A with respect to pathogen, were residuals injected with eight hours after discharge from
pathogen treatment? Yes No
· Was incorporation done six hours after application (Inspection)? Yes No

• Was the appropriate documentation to show pathogen and vector attraction reduction included in the
report? Yes No
• Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503?
Yes No

5. Soil Tests (Class B Supplemental Field Form)
• Was a Standard Soil Fertility Analysis conducted for each application field? Yes No
• Were all the required parameters reported? Yes No
• Were the soil pH’s 6.0 or greater for each application field? Yes No
• If no, was lime applied to those fields if recommended by the Agronomist? Yes No
• Were the copper and zinc indexes in the soil less than 2000 for each application field?
Yes No
• Was sodium less than 0.5 meq, and exchangeable sodium percentage (ESP) less than 15%?
Yes No

6. General
• Was the report in the proper format? Yes No
• Was the annual report complete? Yes No
• Was the report submitted on time? Yes No

Comment: ESP not reported for fields F1 and F2 on SSFA results.
Docusign Envelope ID: 50262AC5-4D2F-489B-84E4-F0FAEE27E644
Pollutant Limits
Pollutant Ceiling
Concentration
Below
Limit
Cumulative Pollutant
Loading Rate
Below
Limit
kg/ha lbs/ac
Arsenic 75 41 36
Cadmium 85 39 34
Copper 4300 1500 1338
Lead 840 300 267
Mercury 57 17 15
Molybdenum 75 N/A N/A
Nickel 420 420 374
Selenium 100 100 89
Zinc 7500 2800 2498
TCLP
Parameter Below
Limit
Parameter Below
Limit
Parameter Below
Limit
Arsenic (5.0) 1,4-Dichlorobenzene (7.5) Nitrobenzene (2.0)
Barium (100.0) 1,2-Dichloroethane (0.5) Pentachlorophenol (100.0)
Benzene (0.5) 1,1-Dichloroethylene (0.7) Pyridine (5.0)
Cadmium (1.0) 2,4-Dinitrotoluene (0.13) Selenium (5.0)
Carbon tetrachloride (0.5) Endrin (0.02) Silver (5.0)
Chlorodane (0.03) Hepatachlor (and its
epoxide) (0.008)
Tetrachloroethylene (0.7)
Chlorobenzene (100.0) Hexachlorobenzene (0.13) Toxaphene (0.5)
Chloroform (6.0) Hexachlorobutadiene (0.5) Trichloroethylene (0.5)
Chromium (5.0) Hexachloroethane (3.0) 2,4,5-Trichlorophenol
(400.0)

m-Cresol (200.0) Lead (5.0) 2,4,6-Trichlorophenol (2.0)
o-Cresol (200.0) Lindane (0.4) 2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0) Mercury (0.2) Vinyl Chloride (0.2)
Cresol (200.0) Methoxychlor (10.0)
2,4-D (10.0) Methyl ethyl Ketone (200.0)
Residuals Analysis
Parameter Analyzed
For
Parameter Analyzed For Parameter Analyzed For
Aluminum Mercury Potassium
Ammonia-
Nitrogen
Molybdenum Selenium
Arsenic Nickel Sodium
Cadmium Nitrate-Nitrite
Nitrogen
SAR
Calcium % TS TKN
Copper pH Zinc
Lead Phosphorus
Magnesium PAN
Soils Analysis
Parameter Analyzed For Parameter Analyzed For Parameter Analyzed For
Acidity ESP Phosphorus
Base Saturation Magnesium Potassium
Calcium Manganese Sodium
CEC % HM Zinc
Copper pH

y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y not F1 and F2
y
y
y
y
y
y
y
y
y
y
y
Docusign Envelope ID: 50262AC5-4D2F-489B-84E4-F0FAEE27E644