NC0021601_Staff Report_20200319

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 5

To: NPDES Unit Non-Discharge Unit Application No.: NC0021601
Attn: Nick Coco Facility name: Tryon WWTP

From: Mikal Willmer
Asheville Regional Office

Note: This form has been adapted from the non-discharge facility staff report to document the review of both non-
discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.

I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? Yes or No
a. Date of site visit: 3/16/2020
b. Site visit conducted by: Mikal Willmer
c. Inspection report attached? Yes or No In LF
d. Person contacted: Deborah Bradley and their contact information: (828) 859 - 5626 ext.
e. Driving directions: Take exit 67 towards Tryon off of I-26 E. Turn right onto 108 W and continue to
Tryon. Turn left on E Howard St (at light near Ford Dealer). Continue on E Howard St. until you reach
the WWTP.
2. Discharge Point(s): (listed point in BIMS is further upstream than actual discharge point)
Latitude:35.212976 Longitude: -82.219250
Latitude: Longitude:
3. Receiving stream or affected surface waters: Vaughn Creek
Classification: C
River Basin and Subbasin No. Broad – 030501015 (Upper Broad)
Describe receiving stream features and pertinent downstream uses: Vaughn Creek is protected for
secondary recreational use and is tributary to the North Pacolet River, also Class C.
II. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
Proposed flow:
Current permitted flow:
2. Are the new treatment facilities adequate for the type of waste and disposal system? Yes or No
If no, explain:
3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? Yes No N/A
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? Yes No N/A
If no, please explain:
DocuSign Envelope ID: 73BA0793-D573-4F14-B46B-BDA1B3C1ACE2
FORM: WQROSSR 04-14 Page 2 of 5
5. Is the proposed residuals management plan adequate? Yes No N/A
If no, please explain:
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? Yes No N/A
If no, please explain:
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? Yes or No
If yes, attach a map showing conflict areas.
8. Is the proposed or existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? Yes No N/A
If yes, attach list of sites with restrictions (Certification B)
Describe the residuals handling and utilization scheme:
10. Possible toxic impacts to surface waters:
11. Pretreatment Program (POTWs only):

III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A
ORC: Deborah Bradley Certificate #: 991330 Backup ORC: Michael Fife Certificate #:1005209
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? Yes or No
If no, please explain:
Description of existing facilities: A 1.5 MGD extended aeration facility which consists of primary screens,
bypass bar screen, parshall flume, extended aeration, two circular secondary clarifiers, chlorine gas with
liquid dechlorination and post aeration. Sludge is sent to a thickener and then to a sludge holding pond
before it’s land applied .
Proposed flow: N/A
Current permitted flow: 1.5 MGD
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.) Facility is well maintained; however, the weir teeth in Clarifier #1 is still in need of replacement. Teeth
in Clarifier #2 have been replaced.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? Yes or No N/A
If no, please explain:
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? Yes or No
If yes, please explain:
5. Is the residuals management plan adequate? Yes or No
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? Yes or No N/A
If no, please explain: Tryon WWTP holds has a Class B permit for the land application of residuals
7. Is the existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? Yes or No
If yes, attach a map showing conflict areas.
DocuSign Envelope ID: 73BA0793-D573-4F14-B46B-BDA1B3C1ACE2
FORM: WQROSSR 04-14 Page 3 of 5
9. Is the description of the facilities as written in the existing permit correct? Yes or No
If no, please explain: The facility does not have an aerobic digester. Tryon utilizes a Thickening Tank and
Sludge Holding Pond.
10. Were monitoring wells properly constructed and located? Yes No N/A
If no, please explain:

DocuSign Envelope ID: 73BA0793-D573-4F14-B46B-BDA1B3C1ACE2
FORM: WQROSSR 04-14 Page 4 of 5
11. Are the monitoring well coordinates correct in BIMS? Yes No N/A
If no, please complete the following (expand table if necessary):
Monitoring Well Latitude Longitude
○ ′ ″ - ○ ′ ″
12. Has a review of all self-monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? Yes or No
Please summarize any findings resulting from this review: No NPDES limit violations since the permit
renewal in 2016. Two monitoring violations in 2018.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
13. Are there any permit changes needed in order to address ongoing BIMS violations? Yes or No
If yes, please explain:
14. Check all that apply:
No compliance issues Current enforcement action(s) Currently under JOC
Notice(s) of violation Currently under SOC Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place? NOD issued during 2017 compliance
inspection. Weirs were severely rusted and it was recommended they be replaced. The Town had put out
bids as of the March 2018 inspection, but the Town Manager indicated a decision would not be made until
the new fiscal year. Update as of latest inspection on 3/16/2020. Complete weir replacement in clarifier #2
and repair of center feed well was completed. Waiting on funding to complete replacement of weir teeth in
clarifier #1.
Have all compliance dates/conditions in the existing permit been satisfied? Yes No N/A
If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
Yes No N/A
If yes, please explain:
16. Possible toxic impacts to surface waters:
17. Pretreatment Program (POTWs only): Tryon WWTP has one SIU (Carolina Yarn Processors)

DocuSign Envelope ID: 73BA0793-D573-4F14-B46B-BDA1B3C1ACE2
FORM: WQROSSR 04-14 Page 5 of 5
IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? Yes or No
If yes, please explain:
2. List any items that you would like the NPDES Unit or Non-Discharge Unit Central Office to obtain through an
additional information request:
Item Reason

3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason

4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason

5. Recommendation: Hold, pending receipt and review of additional information by regional office
Hold, pending review of draft permit by regional office
Issue upon receipt of needed additional information
Issue
Deny (Please state reasons: )

6. Signature of report preparer:

Signature of regional supervisor:

Date:

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
See attached NPDES and Pretreatment inspection reports for any additional comments or observations.
Discussed potential new limits with permittee. Recommend a compliance schedule to allow permittee time to
first assess potential contributions of copper and chloride into the system.

DocuSign Envelope ID: 73BA0793-D573-4F14-B46B-BDA1B3C1ACE2
3/19/2020