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Home My WebLink AboutWQ0019960_CEI_20190513 May 13, 2019 J Robert Boyette City of Marion PO Drawer 700 Marion, NC 28752 SUBJECT: Compliance Inspection Report 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 5/01/2019. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in Non-discharge Permit No. WQ0019960. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report". There were no significant issues or findings noted during the inspection and therefore, a response to this inspection report is not required. 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, Bev Price, Environmental Specialist II Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Larry Carver WQS ARO Server LF G:\WR\WQ\McDowell\Wastewater\Non-discharge\City of Marion\City of Marion Land Application Class B\Inspections\May 1, 2019 CEI\20190513_WQ0019960_CEI 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): 336-957-7878Phone:15704Certification:Dennis KeyPrimary ORC: LA,System Classifications: 24 hour contact name Larry Dean Carver 828-652-8843 On-site representative David W Key 336-957-8909 On-site representative Revonda G. Carter 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: 05/01/2019 12:30PM 02:30PM Beverly Price 828-296-4500 Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Routine Land Application of Residual Solids (503) Compliance Evaluation Question Areas: Miscellaneous Questions Record Keeping Treatment Sampling Land Application Site Pathogen and Vector Attraction Transport (See attachment summary) Page 1 of 5 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0019960 05/01/2019 Compliance Evaluation City of Marion Routine Inspection Summary: The Inspection was conducted by Bev Price of the Asheville Regional Office. Revonda Carter, Tim Horton, David Key and Larry Carver assisted with the inspection. The residuals facility and land application site were inspected. Residuals are held in the aerobic digester prior to land application. There is a stormwater drain in the driveway adjacent to the load-out station. The site was dry and no signs of spillage. There is a drain located under the load-out pipe that drains back to the head of the WWTP. Land application was occurring on Wayne Ross Field R-2 (2.7 acres) at the time of inspection. A public notification sign, fencing and flagged buffers were observed. The midpoint flag for the 400’ house buffer should be reviewed as it appeared to be approximately 385’. Residuals had not been applied to that portion of the field. Overall, the field and land application event appeared to be in compliance with permit requirements. The following comments should be noted: 1.The land application ORC indicated that the tanker holds 6700 gallons and that approximately 13,000 gallons per acre are applied. It is recommended that the tanker be calibrated. 2.Safety measures should be added to the O&M Plan. 3.The Spill Control Plan indicates roadways should be flushed if needed in the event of a spill. If flushing is required, ensure that residuals do not enter surface waters. The Sodium Adsorption Ration (SAR) for the residuals analysis was calculated at 13.4. The calculation was re-checked and determined to be 0.3675. The re-calculated SAR was determined using the Sodium, Calcium, Magnesium & percent solids from data collected on March 5, 2019. In the future, please review all monitoring data to ensure compliance prior to land application events. Land application was halted on May 1st, due to issues with the pump at the digester. The sludge was thicker than anticipated and the pumps could not pump at an acceptable rate Page 2 of 5 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0019960 05/01/2019 Compliance Evaluation 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? Soils analysis is conducted after land application events to determine if lime addition is needed. PAN balances, metals loading and Residual Analysis Summary are reviewed in the Annual Report. The backup ORC reported that the tanker has been calibrated in the past but that is not documented - Calibration is not a permit requirement. Current metals/TCLP data appeared to be compliant with permit limits. The Sodium Adsorption Ration (SAR) was reported at 13.4 - see the inspection summary for further comment. The field is grazed. 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 Page 3 of 5 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0019960 05/01/2019 Compliance Evaluation City of Marion Routine 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) 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: Sampling Yes No NA NE Describe sampling: The WWTP laboratory staff collects samples at the end of the aeration basin for the SOUR analysis. The sample is taken directly to the lab for analysis. TCLP, nutrient and fecal coliform samples are collected from the digester prior to land application. Samples are collected by laboratory staff. Is sampling adequate? Is sampling representative? Comment: Transport Yes No NA NE Is a copy of the permit in the transport vehicle? Is a copy of the spill control plan in the vehicle? Is the spill control plan satisfactory? Does transport vehicle appear to be maintained? Page 4 of 5 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0019960 05/01/2019 Compliance Evaluation City of Marion Routine The land application ORC has a copy of the permit and is on site during application events. Each driver maintains a maintenance log and hauling sheet in the truck. Comment: Land Application Site Yes No NA NE Is a copy of the permit on-site during application events? Is the application site in overall good condition? Is the site free of runoff/ponding? If present, is the application equipment in good operating condition? Are buffers being maintained? Are limiting slopes buffered? 10% for surface application 18% for subsurface application Are there access restrictions and/or signs? Is the application site free of odors or vectors? Have performance requirements for application method been met? For injection? For incorporation? Does permit require monitoring wells? Have required MWs been installed? Are MWs properly located w/ respect to RB and CB? Are MWs properly constructed (including screened interval)? Is the surrounding area served by public water? If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted? Are soil types consistent w/ Soil Scientist report/evaluation? Is the water table greater than 1'/3' bls. Is application occurring at the time of the inspection? The 400' flagged buffer for home southwest of Field R-2 should be verified - currently flagged at approximately 385', only the midpoint flag needs to be reviewed. Water table was not verified; verification is recommended. Seasonal High water table when originally permitted was >6'. Comment: Page 5 of 5 Certificate Of Completion Envelope Id: 6534B6127B94487387C125E7CF84C910 Status: Completed Subject: Please DocuSign: 20190513_WQ0019960_CEI_draft.rtf, 20190513_WQ0019960_INSP_Draft.pdf Source Envelope: Document Pages: 7 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 Bev.Price@ncdenr.gov IP Address: 149.168.204.10 Record Tracking Status: Original 5/13/2019 5:58:35 AM Holder: Beverly Price Bev.Price@ncdenr.gov Location: DocuSign Signer Events Signature Timestamp Beverly Price bev.price@ncdenr.gov North Carolina Department of Environmental Quality Security Level: Email, Account Authentication (None)Signature Adoption: Pre-selected Style Using IP Address: 149.168.204.10 Sent: 5/13/2019 5:59:00 AM Viewed: 5/13/2019 5:59:07 AM Signed: 5/13/2019 5:59:30 AM Freeform Signing Electronic Record and Signature Disclosure: Not Offered via DocuSign In Person Signer Events Signature Timestamp Editor Delivery Events Status Timestamp Agent Delivery Events Status Timestamp Intermediary Delivery Events Status Timestamp Certified Delivery Events Status Timestamp Carbon Copy Events Status Timestamp Witness Events Signature Timestamp Notary Events Signature Timestamp Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted 5/13/2019 5:59:01 AM Certified Delivered Security Checked 5/13/2019 5:59:07 AM Signing Complete Security Checked 5/13/2019 5:59:30 AM Completed Security Checked 5/13/2019 5:59:30 AM Payment Events Status Timestamps