WQ0002127_CEI_20190117

January 17, 2019

Brad E Boris
City of Morganton
PO Box 3448
Morganton, NC 28655-9850

SUBJECT: Compliance Inspection Report
City of Morganton DCAR
Non-discharge Permit No. WQ0002127
Burke County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the City of Morganton DCAR
on 1/04/2019. This inspection was conducted to verify that the facility is operating in compliance with
the conditions and limitations specified in Non-discharge Permit No. WQ0002127. The findings and
comments noted during this inspection are provided in the enclosed copy of the inspection report
entitled "Compliance Inspection Report".

The following non-compliance issue was noted and should be addressed:

Residual/compost leachate runoff to a stormwater drain. The front-end loader used for mixing residuals and
wood chips was parked approximately 100 feet from a stormdrain. It was raining at the time of inspection and
residuals/compost from the front-end loader and on the pavement was entering the drain. Measures should
be taken to ensure residual/compost/leachate stay on the compost pad. Surface waters did not appear to be
impacted.

Recommendation for increased bacteria sampling:

It is highly recommended that the number of bacteria samples collected per monitoring event be increased to
seven over a two-week period. It is also highly recommended that residuals that have been stockpiled beyond
the monitoring frequency period, be resampled for bacteria (7 samples) prior to distribution.

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 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\Burke\Wastewater\Non-discharge\City of Morganton\Inspections\January 4, 2019 CEI Facility\20190117_WQ0002127_CEI.Ltr.docx

Compliance Inspection Report
Permit:WQ0002127 Effective:03/01/18 Expiration:02/28/23 Owner :City of Morganton
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Burke
Asheville
Brad E Boris
Effective:Expiration:Facility:City of Morganton DCAR
1000 Vine Arden Rd
Morganton NC 28655
Title:Phone:[phone]Director Water Resources
I-40 to Exit 105 to Hwy. 18N. Turn rt. on Hwy. 70 By-Pass, turn left @ light to Hwy. 70 W. Turn right on Kirksey Dr. Go approx. 1.25
miles to Vine Arden Road on right.
Secondary ORC(s):
Phone:Certification:Primary ORC:
System Classifications:
24 hour contact name Elisha J Self 828-438-5375
On-site representative Elisha J Self 828-438-5375
On-site representative Shane Roper 828-438-5375
On-Site Representative(s):
Related Permits:
NC0026573 City of Morganton - Catawba River Pollution Control Facility
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
01/04/2019 10:00AM 11:30AM
Beverly Price 828-296-4500
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Distribution of Residual Solids (503)
Compliance Evaluation
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Sampling Pathogen and Vector Attraction
(See attachment summary)
Page:1
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0002127
01/04/2019 Compliance Evaluation
City of Morganton
Routine
Inspection Summary:
The facility inspection was conducted by Beverly Price of the Asheville Regional Office. Shane Roper and Eli Self assisted
with the inspection.
Operation/Maintenance Issue:
Residual/compost leachate runoff to a stormwater drain - The front-end loader used for mixing residuals and wood chips was
parked approximately 100 feet from a stormdrain. It was raining at the time of inspection and residuals/compost from the
front-end loader and on the pavement was entering the drain.
The stormwater runoff did not appear to be impacting surface waters.
According to facility staff, a request was submitted to purchase a mix-box to help ensure a more effective mix of residuals
and wood chips. This issue was mentioned in the last inspection.
According to facility staff, a quote was received for repaving/grading the area at the west end of the residuals mixing shed to
help prevent stormwater from entering the mixing area. Standing water/leaking roof in this area was mentioned in the last
inspection.
Infrastructure issues from the previous facility inspection that the permittee should address:
1.Additional cover for final product storage. Keeping the product dry helps alleviate potential for regrowth/cross
contamination.
2.The gutter downspouts on the south side of the mixing shed should be connected to the floor drains.
Correction from the previous facility inspection: All stormwater drains on the compost pad drain back to the head of the
wastewater treatment plant. Measures should be put in place to ensure the drains on the north side of the mixing shed do
not get clogged and cause leachate to pool.
Sampling:
It is highly recommended that the number of bacteria samples collected per monitoring event be increased to seven over a
two-week period. It is also highly recommended that residuals that have been stockpiled beyond the monitoring frequency
period, be resampled for bacteria (7 samples) prior to distribution.
Page:2
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0002127
01/04/2019 Compliance Evaluation
City of Morganton
Routine
Type Yes No NA NE
Land Application
Distribution and Marketing
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?
TCLP Analysis is required once per permit cycle.
Residuals analyses are from 2018. Residual Analyses and Residual Sampling Summary Form
will be reviewed in the 2018 Annual Report.
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
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0002127
01/04/2019 Compliance Evaluation
City of Morganton
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
There were fecal coliform exceedances in the first and second quarters of 2018. Those
residuals were resampled and results were compliant. The fourth quarter residuals were
sampled in October and were compliant. The residuals were sampled again in mid-December
and exceeded the permit limit. Those residuals were set aside to be landfilled.
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
CentrifugeComment:
Sampling Yes No NA NE
Describe sampling:
The frequency for bacteria and residuals analyses are dependent on the volume of residuals distributed,
usually quarterly. When composted residuals meet required time/temperatures, the pile is screened. 15-20
grab samples are then collected from the screened pile and composited for analyses.
Is sampling adequate?
Is sampling representative?
For bacteria monitoring: it is highly recommended that the number of samples be increased to
seven per monitoring event and that the samples be collected over a two week period. It is also
highly recommended that any residuals that are stockpiled longer than the required monitoring
frequency period be resampled for bacteria prior to distribution.
Comment:
Page:4
Certificate Of Completion
Envelope Id: 9FB34E505DE341E183EEFA7B48090BDF Status: Completed
Subject: Please DocuSign: 20190117_WQ0002127_CEI.Ltr.docx, 20190117_WQ0002127_CEI.draft.pdf
Source Envelope:
Document Pages: 6 Signatures: 1 Envelope Originator:
Certificate Pages: 1 Initials: 1 Beverly Price
AutoNav: Disabled
EnvelopeId Stamping: Disabled
Time Zone: (UTC-08:00) Pacific Time (US & Canada)
217 W. Jones Street
Raleigh, NC 27699
[e-mail]
IP Address: 149.168.204.10
Record Tracking
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1/17/2019 11:39:03 AM
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[e-mail]
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[e-mail]
North Carolina Department of Environmental Quality
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