WQ0003698_Compliance Evaluation Inspection_20100505

MODEM
North Carolina Department of Environment and
Division of'NaterQuafity
Beverly Eaves Perdue ween k- Sullins
Govemor Director
Aquifer Protection Section
May 5, 2010
Robert Boyette
City Manager
City of Marion
P.O. Box 700
Marion, NC 28752
Natural Resources
Dee Freeman
Secretary
Subject: April 28, 2010
Compliance Evaluation Inspection
City of Marion
Corpening Creek WWTP
Surface Disposal of Residual Solids
Permit No: WQ0003698
McDowell County
Dear Mr. Boyette:
Enclosed please find a copy of the Compliance Evaluation Inspection form from the site
visit that Brett Laverty and I conducted on April 28, 2010. The facility was found to be non-
compliant with permit WQ0003698 for the following reasons: Permit Conditions III. 2. & 6.
(Operational Maintenance Requirements). As outlined in your surface disposal unit closure and
post -closure plan (August 2001), the City of Marion has agreed to the following long-term
activities: 0 protect against pit volume settling and ponding, ® maintain a stable soil cap that
promotes runoff and limits infiltration, ® maintain a vegetative cover of perennial grasses and
legumes, and (D the removal of large trees, shrubs, and other woody vegetation.
The Divisions recent investigation of surface disposal units 1 — 5 illustrates the
deteriorating site conditions, which include exposed biosolids, public access/illegal trash
dumping, cap settling/ponding, poor drainage, and the establishment of mature hardwood trees
on the surface disposal units. An additional outcome of the investigation is the lack of
institutional memory of the site in terms of the location and dimension of each surface disposal
unit. It is our intent to have all surface disposal units investigated, documented, and in
compliance within a span of five years.
During the first year, the Division would like to see activity addressing the conditions at
surface disposal units 1-5. All surface disposal units will need trees and stumps pulled from
within the waste boundary. Vegetation outside of the waste boundary need not be addressed.
All surface disposal units will require the addition of cover material to address cap settling.
Disposal units 1 and 2 will need substantial fill material to address thin to non-existent caps. In
N�OlethGvojipa
North Camlina Division of Water Quality —AshevilleRegional Onix 2090 U.S. Highway 70 Swannanoe, NC 28778 phone (828) 29&.4500
Aquifer protection Section - FAX [phone]
Customer Service 1-877-873-6748
Internet h2oeru.state.ncus

Mr. Boyette
May 5, 2010
Page 2
order to promote runoff and limit infiltration, appropriate compaction and shaping of the cap is
encouraged. The cap should be seeded with perennial grasses and legumes.
During the second and third years, the Division would like to see a site assessment
completed on surface disposal units 6 — 8. This would most likely include an adequate number
of depth sounding or auger holes to characterize the cover type/depth, determine depth of
biosolids, and delineate the waste boundary. The condition of each disposal unit cap must also
be evaluated. All data points and waste boundary locations must be documented by IaUlong
coordinates. A site assessment report will be submitted to the Asheville Regional Office (ARO).
The attached October 16, 2009 letter is an example of what we will require in a site assessment
report. Lastly, the Division would like to see activity addressing the conditions at surface
disposal units 6 — 8_ This may entail cutting trees, pulling stumps, and the addition of cover
material. In order to promote runoff and limit infiltration, appropriate compaction and shaping of
the cap is encouraged. The cap should be seeded with perennial grasses and legumes.
During the fourth and fifth years, the Division would like to see a site assessment
completed on surface disposal units 9 - 11. This would most likely include an adequate number
of depth sounding or auger holes to characterize the cover type/depth, determine depth of
biosolids, and delineate the waste boundary. The condition of each disposal unit cap must also
be evaluated. All data points and waste boundary locations must be documented by lat/long
coordinates. A site assessment report will be submitted to the ARO. In addition, a site map will
need to be created showing all surface disposal unit locations, waste boundaries, monitoring
well locations, compliance boundary, review boundary, topography, access roads, and all other
site activities (i.e. stump dump)_ Lastly, the Division would like to see activity addressing the
conditions at surface disposal units 9 - 11. This may entail cutting trees, pulling stumps, and the
addition of cover material. In order to promote runoff and limit infiltration, appropriate
compaction and shaping of the cap is encouraged. The cap should be seeded with perennial
grasses and legumes.
The Division appreciates your professional and prompt attention to these matters.
Please refer to the enclosed inspection report (Inspection Summary — page 2) for additional
observations and comments. If you .or;your staff has any questions, please call me at (828) 296-
4685.
Sincerely,
Beverly nee
Environmental Specialist
Enclosure
Cc: Larry Craver, Wastewater Superintendant
APS Central Files
APS Asheville Files c.