WQ0004298_CEIARR_20171222

State of North Carolina | Environmental Quality | Water Resources
2090 U.S. 70 Highway, Swannanoa, NC 28778
828-296-4500

December 22, 2017

Darhyl Boone, Town Manager
Town of Mars Hill
Post Office Box 368
Mars Hill NC 28754

SUBJECT: Compliance Inspection Report
Annual Report (2016) Review
Town of Mars Hill RLAP
Non-discharge Permit No. WQ0004298
Madison County

Dear Permittee:

The North Carolina Division of Water Resources has completed a review of the 2016 Annual
Report and additional information received on July 19, 2017. This inspection was conducted to
verify that the facility is operating in compliance with the conditions and limitations specified in
Non-discharge Permit No. WQ0004298. The findings and comments noted during this
inspection are provided in the enclosed copy of the inspection report entitled "Compliance
Inspection Report".

The following issues are reminders for Annual Report data:

1. For soils analyses please ensure that the sodium analysis result is reported in the
following units: meq/100cm3 Please also ensure that the Copper (CU) & Zinc (ZN)
Index is included.
2. Please ensure that the analytical method number is included on the Earth Environmental
Services summary data sheet and clarify the units.
3. The Predominant Soil Series for your application fields is listed in the most recent permit
renewal application as Clifton Clay loam. Please use this Soil Series and the correct
Plant Available Nitrogen (PAN) Rate for the corresponding crop type. If applying on
fescue, the PAN rate would be 176 lb/acre. This information (Realistic Yield Expectation
for specific soil type) is available on the NC Department of Agriculture website.
4. Please ensure that the correct alternatives are selected on the Annual Pathogen and
Vector Attraction Reduction Form; the correct Class B Alternative is Alternative # 1 and
the Vector Attraction Reduction Alternative is Alternative #4.

State of North Carolina | Environmental Quality | Water Resources
2090 U.S. 70 Highway, Swannanoa, NC 28778
828-296-4500

If you should have any questions, please do not hesitate to contact me at 828-296-4500 or
via email at [e-mail].

Sincerely,

Beverly Price
Environmental Senior Specialist

ATTACHMENT: Inspection Report

20171222_WQ0004298_CEIARR.rtf
Compliance Inspection Report
Permit:WQ0004298 Effective:07/19/16 Expiration:06/30/21 Owner :Town of Mars Hill
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Madison
Asheville
L Darhyl Boone
Effective:Expiration:Facility:Town of Mars Hill RLAP
504 Cascade St
Mars Hill NC 28754
Title:Phone:[phone]Town Manager
From the intersection of NC Hwy. 213 and NCSR 1609, travel south on NCSR 1609 approximately 1.1 miles until the intersection
with NCSR 1559. Travel southwest on NCSR approximately 0.5 miles until the intersection with NCSR 1560 the site is to north.
Secondary ORC(s):
828-689-2301Phone:14793Certification:Robert M SamsPrimary ORC:
LA,System Classifications:
24 hour contact name Darhyl Boone 828-689-2301
On-Site Representative(s):
Related Permits:
NC0057151 Town of Mars Hill - Mars Hill WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
06/27/2017 10:00AM 11:00AM
Beverly Price 828-296-4500
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 Pathogen and Vector Attraction
(See attachment summary)
Page:1
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0004298
06/27/2017 Annual Report Review
Town of Mars Hill
Routine
Inspection Summary:
The inspection consisted of a review of the 2016 Annual Report. The review was conducted by Beverly Price of the Asheville
Regional Office (ARO).
An additional information request was sent out on July 17, 2017. The following information was requested:
1.Laboratory data sheets from Environmental Testing Solutions.
2.Laboratory data sheets from Waypoint Analytical (A&L Eastern Laboratories).
3.Earth Environmental Services summary data sheet with analytical Method numbers and units clarification.
4.Annual Land Application Field Summary Form showing PAN Rate & Predominant Soil Series.
5.Annual Pathogen & Vector Attraction Reduction Form showing the correct Monitoring Period, the correct Class B
Pathogen Reduction alternative and the correct Vector Attraction Reduction alternative performed in 2016.
Additional Information was received in the ARO on 7/19/2017:
1. Laboratory data sheets for all 2016 analyses conducted by or subcontracted by Environmental Testing Solutions were
submitted.
2. Laboratory data sheets for Waypoint Analytical for 2016 were submitted.
3. The Earth Environmental Services data summary sheet was resubmitted but the parameter units are still not clear.
Method numbers should be included on the data summary sheet.
4. The PAN rate was incorrect. The PAN rate depends on the soil and crop type.
5. The correct alternative for Class B residuals should be indicated on the Pathogen and Vector Attraction Reduction Form.
18.821 dry tons of residuals were land applied to 14.5 permitted acres (Matthew Cody Field #1). Nutrients/metals, Pathogen
Reduction/Vector Attraction Reduction (VAR) and soils analyses were conducted according to the permit requirements.
Permit limits for metals (Ceiling Concentrations and Cumulative Pollutant Loading Rates), and PAN appear to have been
met. The application field showed pH above 6.
Page:2
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0004298
06/27/2017 Annual Report Review
Town of Mars Hill
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?
Metals/nutrient analyses are for 2016.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)
Temperature corrected
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
Page:3
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0004298
06/27/2017 Annual Report Review
Town of Mars Hill
Routine
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench-top Aerobic/Anaerobic digestion results
Comment:
Page:4