NC0021601_PCI & CEI_20200319

March 19, 2020

Zach Ollis
Town of Tryon
301 N Trade St
Tryon, NC 28782

SUBJECT: Compliance Inspection Report & PCI
Tryon WWTP
NPDES WW Permit No. NC0021601
Polk County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Tryon WWTP and pretreatment
program on 3/16/2020. This inspection was conducted to verify that the facility is operating in compliance
with the conditions and limitations specified in NPDES WW Permit No. NC0021601. The findings and
comments noted during this inspection are provided in the enclosed copy of the inspection report entitled
"Compliance Inspection Report".

If you should have any questions, please do not hesitate to contact me at 828-296-4686 or via email at
[e-mail].

Sincerely,

Mikal Willmer, Environmental Specialist II
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: CEI & PCI

EC: WQS-ARO Server, LF
Deborah Bradley, ORC
G:\WR\WQ\Polk\Wastewater\Municipal\Tryon WWTP 21601\Inspections\CEI 3-16-2020\NC0021601_CEI_PCI_20200319

DocuSign Envelope ID: CF9C60C3-ACDA-4670-AC64-1ECE7AEE776E
EPA
United States Environmental Protection Agency
Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 N 52 NC0021601 20/03/16 C S31112171819 20
21 66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
N67707172 73 74 75 80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Tryon WWTP
1526 E Howard St
Tryon NC 28782
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
09:00AM 20/03/16 16/06/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Deborah M Bradley/ORC/828-859-5626/
Michael Justin Fife/ORC/825-859-8626/
Other Facility Data
11:00AM 20/03/16 18/12/31
Name, Address of Responsible Official/Title/Phone and Fax Number
Deborah Bradley, /ORC/828-894-2048/Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self-Monitoring Program Sludge Handling Disposal Pollution Prevention Facility Site Review
Pretreatment Effluent/Receiving Waters Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s)Agency/Office/Phone and Fax Numbers Date
Mikal Willmer DWR/Division of Water Quality/828-296-4686/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#1
DocuSign Envelope ID: CF9C60C3-ACDA-4670-AC64-1ECE7AEE776E
3/19/2020
3/19/2020
NPDES yr/mo/day
20/03/16
Inspection Type
C3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Inspector Mikal Willmer, with the Asheville Regional Office, conducted a compliance evaluation
inspection of the Tryon WWTP on March 16, 2020. This inspection was conducted to determine
whether the facility is operating in compliance with NPDES Permit No. NC0021601. Deborah Bradley
(ORC) and Michael Fife (BORC) were present and assisted in the inspection.
The facility appeared to be in compliance at the time of the inspection. Comments/recommendations
are listed below.
Maintenance: The Town has been taking active steps to improve facility performance and make repairs.
Since the last inspection in 2018, the weirs and center feed well in clarifier #2 have been repaired, two
new pumps have been installed in the scum box and RAS pumps have been rehabilitated. The weir
teeth in clarifier #1 still need to be replaced and should be kept in the budget to be completed once
major deficiencies in the collection system are addressed.
Flow: Staff report average flows are 0.25 MGD and currently no new growth or expansion within the
system. Continue to assess the current mechanical bar screen. Mr. Fife and Ms. Bradley indicated the
mechanical screen has issues handling flows above 0.7 MGD. The facility is rated for 1.5 MGD. A
reduction in I&I from the collection system would reduce these flow swings. The Town is currently
working on projects within the CS.
Chlorine/Dechlor: Facility utilizes chlorine gas a liquid calcium thisoulfate solution. Chlorine Sales &
Services replaces all tubing and calibrates feed equipment once a year. Feeds were flow paced;
however, the system had trouble consistently feeding small doses, so it is now a manual feed. Staff
report they do not have to adjust feed rates too often. If manually feeding, more process control checks
during rain events is recommended to maintain adequate disinfection. Solids are removed
approximately once a year from the contact chamber.
Receiving Stream: no visual impacts noted at the time of the inspection. The foam observed in 2018
was not observed during this inspection.
NC0021601 17 (Cont.)
Page#2
DocuSign Envelope ID: CF9C60C3-ACDA-4670-AC64-1ECE7AEE776E
Permit:NC0021601
Inspection Date:03/16/2020
Owner - Facility:
Inspection Type:
Tryon WWTP
Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
DO, pH, setteable solids, MLSSComment:
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
application?
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
See staff report for updates to current treatment components/description. Permit is in
renewal since 2018 and draft is forthcoming.
Comment:
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain-of-custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility classification?
Is the backup operator certified at one grade less or greater than the facility classification?
Is a copy of the current NPDES permit available on site?
Page#3
DocuSign Envelope ID: CF9C60C3-ACDA-4670-AC64-1ECE7AEE776E
Permit:NC0021601
Inspection Date:03/16/2020
Owner - Facility:
Inspection Type:
Tryon WWTP
Compliance Evaluation
Record Keeping Yes No NA NE
Facility has copy of previous year's Annual Report on file for review?
Comment:
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment:
Flow Measurement - Effluent Yes No NA NE
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Facility uses influent flow meter for reporting. Matt Lassiter calibrates meters annually in
December.
Comment:
Solids Handling Equipment Yes No NA NE
Is the equipment operational?
Is the chemical feed equipment operational?
Is storage adequate?
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
Is the site free of sludge buildup on belts and/or rollers of filter press?
Is the site free of excessive moisture in belt filter press sludge cake?
The facility has an approved sludge management plan?
Facility maintains a Class B permit (WQ0004341) with dedicated fields. Additionally, the
Town is pursuing additional fields to add to their permit.
Comment:
Bar Screens Yes No NA NE
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Page#4
DocuSign Envelope ID: CF9C60C3-ACDA-4670-AC64-1ECE7AEE776E
Permit:NC0021601
Inspection Date:03/16/2020
Owner - Facility:
Inspection Type:
Tryon WWTP
Compliance Evaluation
Bar Screens Yes No NA NE
Is disposal of screening in compliance?
Is the unit in good condition?
Mechanical screen can accomodate flows up to approximately 700,000 gallons and then the
manual screen has to be used. This is usually only during rain events due to I&I within the
collection system.
Comment:
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Is the site free of excessive floating sludge?
Is the drive unit operational?
Is the return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable? (Approximately ¼ of the sidewall depth)
Clarifier #2: Weirs were replaced, and repairs were made to the center feed well. Clarifier
#1: Weir teeth still need to be replaced; however, other wastewater infrastructure projects
have temporarily taken priority. Appears to be even flow over rusting weirs and no visual
pin-floc or solids exiting the clarifiers at the time of the inspection.
Comment:
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Surface
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin’s surface?
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/l)
One active and one inactive Aeration Basin. Staff indicate they attempt to keep DOs below 3
mg/L in the active aeration basin. Wastewater is tinted due to contributions from IU CYP.
Comment:
Page#5
DocuSign Envelope ID: CF9C60C3-ACDA-4670-AC64-1ECE7AEE776E
Permit:NC0021601
Inspection Date:03/16/2020
Owner - Facility:
Inspection Type:
Tryon WWTP
Compliance Evaluation
De-chlorination Yes No NA NE
Type of system ?Liquid
Is the feed ratio proportional to chlorine amount (1 to 1)?
Is storage appropriate for cylinders?
# Is de-chlorination substance stored away from chlorine containers?
Are the tablets the proper size and type?
Use calcium thiosulfate.Comment:
Are tablet de-chlorinators operational?
Number of tubes in use?
Comment:
Pumps-RAS-WAS Yes No NA NE
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
RAS pumps rehabed.Comment:
Standby Power Yes No NA NE
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Is the generator tested under load?
Was generator tested & operational during the inspection?
Do the generator(s) have adequate capacity to operate the entire wastewater site?
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
Is the generator fuel level monitored?
Fuel is checked regularly and tests automatically every other week.Comment:
Influent Sampling Yes No NA NE
# Is composite sampling flow proportional?
Is sample collected above side streams?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Page#6
DocuSign Envelope ID: CF9C60C3-ACDA-4670-AC64-1ECE7AEE776E
Permit:NC0021601
Inspection Date:03/16/2020
Owner - Facility:
Inspection Type:
Tryon WWTP
Compliance Evaluation
Influent Sampling Yes No NA NE
Is sampling performed according to the permit?
Comment:
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
Comment:
Aerobic Digester Yes No NA NE
Is the capacity adequate?
Is the mixing adequate?
Is the site free of excessive foaming in the tank?
# Is the odor acceptable?
# Is tankage available for properly waste sludge?
Facility does not have a digester. Facility utilizes a thickener and sludge holding pond before
land application of residuals
Comment:
Disinfection-Gas Yes No NA NE
Are cylinders secured adequately?
Are cylinders protected from direct sunlight?
Is there adequate reserve supply of disinfectant?
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de-chlorination?
Does the Stationary Source have more than 2500 lbs of Chlorine (CAS No. 7782-50-5)?
If yes, then is there a Risk Management Plan on site?
If yes, then what is the EPA twelve digit ID Number? (1000-____-____)
If yes, then when was the RMP last updated?
Page#7
DocuSign Envelope ID: CF9C60C3-ACDA-4670-AC64-1ECE7AEE776E
Permit:NC0021601
Inspection Date:03/16/2020
Owner - Facility:
Inspection Type:
Tryon WWTP
Compliance Evaluation
Disinfection-Gas Yes No NA NE
Comment:
Page#8
DocuSign Envelope ID: CF9C60C3-ACDA-4670-AC64-1ECE7AEE776E
EPA
United States Environmental Protection Agency
Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 N 52 NC0021601 20/03/16 P S31112171819 20
21 66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
N67707172 73 74 75 80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Tryon WWTP
1526 E Howard St
Tryon NC 28782
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
09:00AM 20/03/16 16/06/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Deborah M Bradley/ORC/828-859-5626/
Other Facility Data
11:00AM 20/03/16 18/12/31
Name, Address of Responsible Official/Title/Phone and Fax Number
Deborah Bradley, /ORC/828-894-2048/Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Other
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s)Agency/Office/Phone and Fax Numbers Date
Mikal Willmer DWR/Division of Water Quality/828-296-4686/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#1
DocuSign Envelope ID: CF9C60C3-ACDA-4670-AC64-1ECE7AEE776E
3/19/2020
3/19/2020
NPDES yr/mo/day
20/03/16
Inspection Type
P3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Mikal Willmer, with the Asheville Regional Office, conducted a pretreatment compliance inspection
(PCI) of the Town of Tryon's Pretreatment program on March 16, 2020. This inspection was conducted
in conjunction with the WWTP's facility inspection. Deborah Bradley (ORC) and Michael Fife (BORC)
were present and assisted in the inspection.
All monitoring and reporting appear to be in compliance. The program only has one SIU, Carolina Yarn
Processors (CYP). CYP had one BOD limit exceedance in April of 2019, which has since been
resampled and resolved. No outstanding issues with CYP were noted at the time of the inspection.
CYPs most recent industrial inspection indicated they were no longer dying yarn. See attached PCI
form for additional details about system performance since the last inspection in 2018.
NC0021601 17 (Cont.)
Page#2
DocuSign Envelope ID: CF9C60C3-ACDA-4670-AC64-1ECE7AEE776E
Permit:NC0021601
Inspection Date:03/16/2020
Owner - Facility:
Inspection Type:
Tryon WWTP
Pretreatment Compliance
Other Yes No NA NE
See summary.Comment:
Page#3
DocuSign Envelope ID: CF9C60C3-ACDA-4670-AC64-1ECE7AEE776E
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT

BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Tryon
2. Control Authority Representative(s): Deborah Bradley/Michael Fife
3. Title(s): Pretreatment Coordinator/ORC/BORC
4. Last Inspection Date: 03/08/2018 Inspection Type (Check One): PCI Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? YES NO NA
6. Is POTW under an Order That Includes Pretreatment Conditions? YES NO
Order Type, Number, Parameters: _______________________________ Are Milestone Dates Being Met? YES NO

ICIS CODING
Main Program Permit Number MM/DD/YY
| N | C | 0 | 0 | 2 | 1 | 6 | 0 | 1 | | 03 | 16 | 20 |

7. Current Number Of Significant Industrial Users (SIUs)? 1
8. Number of SIUs With No IUP, or With an Expired IUP ? 0
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year? 0
10. Number of SIUs Not Sampled By POTW in the Last Calendar Year? 0
11. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual
Periods?
0
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods? 0
13. Number of SIUs in SNC with Pretreatment Schedule? 0
14. Number of SIUs on Schedules? 0
15. Current Number Of Categorical Industrial Users (CIUs)? 0
16. Number of CIUs in SNC? 0

POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations?
If Yes, What are the Parameters and How are these Problems Being Addressed?
YES NO

18. Since the Last PCI, has the POTW had any Problems Related to an Industrial
Discharge (Interference, Pass-Through, Blockage, Citizens’ Complaints, Increased
Sludge Production, Etc.)?
If Yes, How are these Problems Being Addressed?
YES NO

19. Which Industries have been in SNC for Limits or Reporting during
either of the Last 2 Semi-Annual Periods? Not Been Published for
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
SNC for Limits:0
SNC for Reporting:0
Not Published:N/A
20. Which Industries are on Compliance Schedules or Orders? For all SIUs on an
Order, Has a Signed Copy of the Order been sent to the Division?

0

21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
YES NO

LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? YES NO
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? YES NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? YES NO Is Table Adequate? YES NO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? YES NO Inspector, please verify yourself!
26. If NO to 23 - 26, list violations _______________________________________________________________________________
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? YES NO
If yes, which ones? Eliminated: Added:_______________________

DocuSign Envelope ID: CF9C60C3-ACDA-4670-AC64-1ECE7AEE776E
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2
28. PRETREATMENT PROGRAM ELEMENTS REVIEW- Please review POTW files, verify POTW has copy of Program Element
in their files, complete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Program Info:
Program Element Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA) 08/03/2018 Yes No 08/15/2018 Yes No 09/30/2023
Industrial Waste Survey (IWS) 05/30/2018 Yes No 06/06/2018 Yes No 05/01/2023
Sewer Use Ordinance (SUO) 1/22/2013 Yes No 4/02/2013 Yes No
Enforcement Response Plan (ERP) 6/24/2016 Yes No 9/07/2016 Yes No
Long Term Monitoring Plan (LTMP) 12/05/2017 Yes No 01/29/2018 Yes No
________________________________________________________________________________________________________________
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. Carolina Yarn Processors 2. 3.
30. IUP Number 001
31. Does File Contain Current Permit? Yes No Yes No Yes No
32. Permit Expiration Date 12/31/2021
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A N/A
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
Yes No Yes No Yes No
35. Does File Contain an Inspection Completed Within Last Calendar Year? Yes No Yes No Yes No
36. a. Does the File Contain a Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. Yes No
b. Yes No
a. Yes No
b. Yes No
a. Yes No
b. Yes No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
Yes No N/A Yes No N/A Yes No N/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. Yes No
b.Yes No N/A
a. Yes No
b.Yes No N/A
a. Yes No
b.Yes No N/A
39. During the Most Recent Semi-Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
Yes No Yes No Yes No
40. Does File Contain POTW Sampling Chain -Of-Custody Forms? Yes No Yes No Yes No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
Yes No N/A Yes No N/A Yes No N/A
41b. During the Most Recent Semi-Annual Period, Did SIU submit all reports
on time?
Yes No N/A Yes No N/A Yes No N/A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
Yes No N/A Yes No N/A Yes No N/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
Yes No N/A Yes No N/A Yes No N/A
43a. During the Most Recent Semi-Annual Period, Did the POTW Identify
All Limits Non-Compliance from Both POTW and SIU Sampling?
Yes No Yes No Yes No
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non-Compliance from SIU Sampling?
Yes No N/A Yes No N/A Yes No N/A
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
c. If applicable, Did POTW resample within 30 days of becoming aware
of SIU limit violations in the POTW’s sampling of the SIU?
a.Yes No N/A

b.Yes No N/A

c.Yes No N/A
a.Yes No N/A

b.Yes No N/A

c.Yes No N/A
a.Yes No N/A

b.Yes No N/A

c.Yes No N/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC? Yes No Yes No Yes No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
Yes No N/A Yes No N/A Yes No N/A
48. Does the File Contain Penalty Assessment Notices? Yes No N/A Yes No N/A Yes No N/A
49. Does The File Contain Proof Of Penalty Collection? Yes No N/A Yes No N/A Yes No N/A
50. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.Yes No N/A
b.Yes No N/A
a.Yes No N/A
b.Yes No N/A
a.Yes No N/A
b.Yes No N/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
Yes No Yes No Yes No

DocuSign Envelope ID: CF9C60C3-ACDA-4670-AC64-1ECE7AEE776E
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3
FILE REVIEW COMMENTS:
CYP had one BOD limit violation of their IUP in April of 2019. Facility resampled and results were within compliance. An updated STMP
was submitted and approved. New STMP sampling will begin in 2022.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
| N | C | 0 | 0 | 2 | 1 | 6 | 0 | 1 | | 03 | 16 | 20 |

1. Industry Inspected: File review only. See comments below.
2. Industry Address: 250 Scrivens Rd, Tryon
3. Type of Industry/Product: Textiles-yarn and bandanas
4. Industry Contact: David Moore Title: President Phone: [phone]
5. Does the POTW Use the Division Model Inspection Form or Eq uivalent? YES NO
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview YES NO
B. Plant Tour YES NO
C. Pretreatment Tour YES NO
D. Sampling Review YES NO
E. Exit Interview YES NO
Industrial Inspection Comments:
File review only. A pretreatment audit was conducted in May of 2016, NPDES inspection of CYP was conducted in August 2016 and a PCI
in January of 2018. No reported issues related to CYP. Tryon conducted an industry inspection on September 17, 2019. It was noted CYP
discontinued yarn dying.

OVERALL SUMMARY AND COMMENTS:
Comments: Paperwork is well organized.
Requirements:
Recommendations: Due to upcoming permit limits for chloride and copper; recommend assessing waste stream to determine if there are
any other potential contributions within the collection system.
NOD: YES NO
NOV: YES NO
QNCR: YES NO
POTW Rating:
Satisfactory X Marginal UnSatisfactory
PCI COMPLETED BY: Mikal Willmer -ARO DATE: 03/16/2020

DocuSign Envelope ID: CF9C60C3-ACDA-4670-AC64-1ECE7AEE776E
3/19/2020
Certificate Of Completion
Envelope Id: CF9C60C3ACDA4670AC641ECE7AEE776E Status: Completed
Subject: Please DocuSign: NC0021601_CEI_PCI_20200319.ltr.docx, NC0021601_CEI_PCI_20200319.insp.pdf, NC00...
Source Envelope:
Document Pages: 15 Signatures: 6 Envelope Originator:
Certificate Pages: 2 Initials: 0 Mikal Willmer
AutoNav: Enabled
EnvelopeId Stamping: Enabled
Time Zone: (UTC-05:00) Eastern Time (US & Canada)
217 W. Jones Street
Raleigh, NC 27699
[e-mail]
IP Address: 149.168.204.10
Record Tracking
Status: Original
Mar 19, 2020 | 14:28
Holder: Mikal Willmer
[e-mail]
Location: DocuSign
Signer Events Signature Timestamp
Mikal Willmer
[e-mail]
Environmental Specialist
North Carolina Department of Environmental Quality
Security Level: Email, Account Authentication
(None)
Signature Adoption: Drawn on Device
Using IP Address: 149.168.204.10
Sent: Mar 19, 2020 | 14:30
Viewed: Mar 19, 2020 | 14:30
Signed: Mar 19, 2020 | 14:31
Electronic Record and Signature Disclosure:
Not Offered via DocuSign
G. Landon Davidson
[e-mail]
Asheville Regional Office, Regional Supervisor
DEQ, Division of Water Resources, Water Quality
Regional Operatoins
Security Level: Email, Account Authentication
(None)
Signature Adoption: Uploaded Signature Image
Using IP Address: 149.168.204.10
Sent: Mar 19, 2020 | 14:31
Viewed: Mar 19, 2020 | 14:31
Signed: Mar 19, 2020 | 14:31
Electronic Record and Signature Disclosure:
Not Offered via DocuSign
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Envelope Sent Hashed/Encrypted Mar 19, 2020 | 14:31
Certified Delivered Security Checked Mar 19, 2020 | 14:31
Signing Complete Security Checked Mar 19, 2020 | 14:31
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Completed Security Checked Mar 19, 2020 | 14:31
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