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Home My WebLink AboutWQ0019960_Compliance Evaluation Inspection_20181206 North Carolina Department of Environmental Quality | Division of Water Resources 2090 U.S. 70 Highway, Swannanoa, NC 28778 828-296-4500 December 06, 2018 J Robert Boyette City of Marion PO Drawer 700 Marion, NC 28752 SUBJECT: Compliance Inspection Report Annual Report (2017) Review Inspection City of Marion RLAP Non-discharge Permit No. WQ0019960 McDowell County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the City of Marion RLAP on 11/30/2018. 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. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report". The following items were noted during the review and should be addressed: 1. The pH analyzed on February 21, 2017, was analyzed out of hold time. The hold time for pH analysis is 15 minutes from the time of collection. 2. The Standard Soil Fertility analysis showed one field with pH 5.9. The Field Summary Form did not indicate that lime had been added to that field. The permit states that bulk residuals shall not be land applied if the soil pH is not maintained at 6.0 or greater, unless sufficient amounts of lime are applied to achieve a final soil pH of at least 6.0, or if an agronomist provides information indicating that the pH of the soil, residuals and lime mixture is suitable for the specified crop. North Carolina Department of Environmental Quality | Division of 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 bev.price@ncdenr.gov. Sincerely, Beverly Price, Environmental Specialist II Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Ec: WQS ARO Server LF G:\WR\WQ\McDowell\Wastewater\Non-discharge\City of Marion\City of Marion Land Application Class B\Inspections\November 30, 2018 CEIARR 2017\20181206_WQ0019960_CEIARR.rtf Compliance Inspection Report Permit:WQ0019960 Effective:08/01/16 Expiration:07/31/21 Owner :City of Marion SOC: Contact Person: Region: County: Directions to Facility: McDowell Asheville J Robert Boyette Effective:Expiration:Facility:City of Marion RLAP 3982 Hwy 226 S Marion NC 28752 Title:Phone:828-652-3551City Manager From ARO: I-40 East to Exit 86. Turn left onto Hwy. 226 south. WWTP is approximately 1/2 mile on the right. David W Key 23629 336-957-7869 Secondary ORC(s): 336-957-8909Phone:15704Certification:Dennis KeyPrimary ORC: LA,System Classifications: 24 hour contact name Larry Dean Carver 828-652-8843 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: 11/30/2018 03:00PM 04:30PM 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 Treatment Pathogen and Vector Attraction (See attachment summary) Page:1 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0019960 11/30/2018 Annual Report Review City of Marion Routine Inspection Summary: The Annual Report Review was conducted by Beverly Price of the Asheville Regional Office. 94.34 dry tons of residuals were land applied in 2017 to six permitted fields (Mario DeLuca #K1 & K2; John Fisher #F1, F2, F3 & F4). Metals/nutrients analyses were conducted as required by the permit. Heavy metals were within ceiling concentration limits. TCLP, Ignitability (SW 846 Method 1010, >212 deg F) Corrosivity (analyzed out of hold time), Reactivity analyses were conducted in 2017. Metals and PAN loading rates appeared to be calculated correctly and within permit limits. Pathogen Reduction was accomplished using Alternative 1 (Fecal Coliform Density). Vector Attraction Reduction (VAR) was accomplished using the Specific Oxygen Uptake Rate (SOUR). The Geometric Mean and SOUR calculations appear to be correct. A Standard Soil Fertility Analysis was conducted for each field receiving residuals. Three fields had pH >6. Three fields had pH<6; two of those fields had lime applications in November 2017. Field #4 (John Fisher) had a pH of 5.9 but did not receive any lime according to the Field Summary Form. The Exchangeable Sodium Percentage (ESP) was <15% for all fields. Page:2 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0019960 11/30/2018 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? Nutrients/metals data are from 2017. Application did not occur during a Seasonal Restriction window. 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 Page:3 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0019960 11/30/2018 Annual Report Review City of Marion Routine 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 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