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Home My WebLink AboutNC0021601_PA_20220406 SENT VIA ELECTRONIC MAIL ONLY: NO HARDY COPY WILL BE MAILED April 06, 2022 Zach Ollis Email: manager@tryonnc.gov Town of Tryon SUBJECT: Pretreatment Audit Tryon WWTP NPDES WW Permit No. NC0021601 Polk County Dear Permittee: The North Carolina Division of Water Resources conducted Pretreatment Audit of the Town of Tryon’s Pretreatment Program on 3/15/2022. 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". 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 828-296-4686 or via email at mikal.willmer@ncdenr.gov. Sincerely, Mikal Willmer, Environmental Specialist II Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Pretreatment Audit Ec: LF Deborah Bradley, ORC & Pretreatment Coordinator DocuSign Envelope ID: 93FCA9D7-84A1-4B5C-A6BF-0DC063D3428B 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 22/03/15 G 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 22/03/15 20/08/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Deborah M Bradley/ORC/828-859-5626/ Other Facility Data 11:30AM 22/03/15 24/12/31 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) Pretreatment 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: 93FCA9D7-84A1-4B5C-A6BF-0DC063D3428B 4/7/2022 4/7/2022 NPDES yr/mo/day 22/03/15 Inspection Type G3111218 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 Audit of the Town of Tryon’s Pretreatment Program. This Audit was conducted on March 15 and March 22 to determine if the program is being maintained with all State and Federal requirements. Deborah Bradley and Michael Fife (Town of Tryon), and Naiden Kremenliev and James Bradley (Tryon Finishing) were present and assisted in the inspection. All paperwork was readily available for review and maintained within the WWTP office. It appears all sampling and follow-up sampling is being completed as required by Tryon Finishing’s IUP. There have been exceedances for BOD and Copper over the past two years; however, staff indicate this does not appear to be a chronic issue. Please note, the Town should continue to monitor exceedances and their cause closely to determine if process changes are warranted. It is recommended the Town split samples with Tryon Finishing when the POTW conducts its annual sampling. Also, as discussed during the pretreatment audit, if the Town determines through monitoring that they are unable to consistently meet their new chloride and copper limits, a modification to the IUP may be warranted. There are currently no apparent issues with allocation. Tryon Finishing is the only SIU and staff indicate there are no known industries opening in Town. NC0021601 17 (Cont.) Page#2 DocuSign Envelope ID: 93FCA9D7-84A1-4B5C-A6BF-0DC063D3428B Permit:NC0021601 Inspection Date:03/15/2022 Owner - Facility: Inspection Type: Tryon WWTP Pretreatment Audit Yes No NA NE Page#3 DocuSign Envelope ID: 93FCA9D7-84A1-4B5C-A6BF-0DC063D3428B NC DWR Pretreatment Audit Form Revised: December 2016 Page 1 NORTH CAROLINA DIVISION OF WATER RESOURCES PRETREATMENT AUDIT REPORT Background Information [Complete prior to audit; review Program Info Database Sheet(s)] 1. Control Authority (POTW) Name: Town of Tryon 2. Control Authority Representative(s): Deborah Bradley 3. Title(s): WWTP ORC & Pretreatment Coordinator 4. Address of POTW: 1526 E Howard St. Tryon NC Mailing 301 N Trade St. City Tryon Zip Code 28782 Phone Number 828-859-5626 Fax Number E-Mail debmbradley@hotmail.com 5. Audit Date 03/15/2022 6. Last Inspection Date: 03/16/2020 Inspection Type: PCI Audit 7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? Yes No NA If No, Explain. 8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? Yes No If Yes, Explain. SIU was in SNC for BOD and Copper in 2020. The Town received an NOD for failure to issue a public notice for the SNC; however, the Town immediately posted the SNC status in the local paper once notified of the deficiency. 9. Is POTW under an Order That Includes Pretreatment Conditions? Yes No Order Type and Number: Are Milestone Dates Being Met? Yes No NA Parameters Covered Under Order ICIS Coding Main Program Permit Number MM/DD/YY N C 0 0 2 1 6 0 1 3 22 22 10. Current Number of Significant Industrial Users (SIUs)? 1 11. Number of SIUs with No IUP, or with an Expired IUP? 0 12. Number of SIUs Not Inspected by POTW in Last Calendar Year? 0 13. Number of SIUs Not Sampled by POTW in Last Calendar Year? 0 14. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods? 0 15. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods? 0 16. Number of SIUs in SNC with Pretreatment Schedule? 0 17. Number of SIUs on Schedules? 0 18. Current Number of Categorical Industrial Users (CIUs)? 0 19. Number of CIUs in SNC? 0 DocuSign Envelope ID: 93FCA9D7-84A1-4B5C-A6BF-0DC063D3428B NC DWR Pretreatment Audit Form Revised: December 2016 Page 2 20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element in their File, complete with all supporting documents and 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) 8/3/18 Yes No 8/15/18 Yes No 9/30/23 Industrial Waste Survey (IWS) 5/30/18 Yes No 6/6/18 Yes No 5/1/23 Sewer Use Ordinance (SUO) 1/22/13 Yes No 4/2/13 Yes No Enforcement Response Plan (ERP) 6/1/20 Yes No 9/2/20 Yes No Long Term Monitoring Plan (LTMP) 12/5/17 Yes No 1/29/18 Yes No Legal Authority (Sewer Use Ordinance-SUO) 21. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction? Yes No If yes, Please list these towns and/or areas. 22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? Yes No NA A copy, if not already submitted, should be sent to Division. 23. If yes to #21, Have you had any trouble working with these towns or districts? Yes No NA If yes, Explain. 24. Date of Last SUO Adoption by Local Council 05/21/2018 25. Have you had any problems interpreting or enforcing any part of the SUO? Yes No If yes, Explain. Enforcement (Enforcement Response Plan-ERP) 26. Did you send a copy of the ERP to your industries? Yes No If no, POTW must send copy within 30 days. 27. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc? Yes No If yes, Explain. 28. List Industries under a Schedule or Order and Type of Schedule or Order Resources 29. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory Rating Explanation, if Unsatisfactory Personnel Available for Maintaining POTW’s Pretreatment Program S M U Access to POTW Vehicles for Sampling, Inspections, and Emergencies S M U Town Truck Access to Operable Sampling Equipment S M U Availability of Funds if Needed for Additional Sampling and/or Analysis S M U Reference Materials S M U Staff Training (i.e. Annual and Regional Workshops, Etc.) S M U ORC hopes to send Mr. Fife to in person training when offered. Computer Equipment (Hardware and Software) S M U DocuSign Envelope ID: 93FCA9D7-84A1-4B5C-A6BF-0DC063D3428B NC DWR Pretreatment Audit Form Revised: December 2016 Page 3 30. Does the POTW have an adequate data management system to run the pretreatment program? Yes No Explain Yes or No. Utilize excel workbooks and maintain paper copies of documents in binders. 31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. Town has surcharge rates within their SUO; however, the primary source of income is water usage. Public Perception/ Participation 32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)? Yes No If yes, Explain. 33. Has anyone from the public ever requested to review pretreatment program files? Yes No If yes, Explain procedure. If no, how would the request be addressed? The pretreatment coordinator would have them come to WWTP office where all documents are retained. 34. Has any industry ever requested that certain information remain confidential from the public? Yes No If yes, Explain procedure for determining whether information qualified for confidential status, as well as procedure for keeping files confi dential from public. If no how would the request be addressed? If requested, the confidential material would be labeled as such and stored separately from the public documents at the WWTP. 35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? Yes No Staff meet with Tryon Finishing regularly to discuss sampling and any planned changes/issues. 36. Is the public notified about changes in the SUO or Local Limits? Yes No 37. Were all industries in SNC published in the last notice? Yes No NA SIU was not in SNC during 2021 monitoring year. SIU was in SNC for 2020 but was posted late. This has since been resolved. Permitting (Industrial Waste Survey-IWS) 38. How does the POTW become aware of new or changed Users? Zoning, Billing, Town Hall and SIU notifies them of any process changes. 39. Once the POTW becomes aware of new or changed Users, how does the POTW determine which industries have the reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an SIU?) If they are not a CIU by definition, then it is based on sampling data and submitted waste stream constituents. 40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate? Yes No If Yes, How many are there? Please list each site and how it is permitted, if applicable. 41. Does the POTW accept waste by (mark if applicable) Truck Dedicated Pipe NA 42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn, manifests required) 43. How does the POTW allocate its loading to industries? Mark all that apply Uniform Limits Historical Industry Need By Surcharge Categorical Limits Other Explain Other: 44. Review POTW’s copies of current allocation tables for each WWTP. Are there any over allocations? Yes No If yes, what parameters are over allocated? 45. If yes to #44, What is being done to address the over allocations? (short -term IUPs, HWA to be revised, pollutant study, etc.) 46. Does the POTW keep pollutant loading in reserve for future growth / safety? Yes No If yes, what percentage of each parameter %Currently not an issue due to only one SIU. Allocations would be redistributed if this changes and/or there are concerns with constituents. 47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) Yes No DocuSign Envelope ID: 93FCA9D7-84A1-4B5C-A6BF-0DC063D3428B NC DWR Pretreatment Audit Form Revised: December 2016 Page 4 If yes, Explain. 48. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (for example : were only those pollutants listed on the application limited; categorical parameters; NPDES Pollutants of Concern) For current SIU, it is pollutants of concern. 49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain. Based on concentration of pollutants and potential to adversely impact the WWTP. Permit Compliance 50. Does the POTW currently have or during the past year had any permits under adjudication ? Yes No If yes, which industries? What was (will be) the outcome of the adjudication? 51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporti ng requirements, and permit conditions, as well as for SNC. NOVs and Public Notices. 52. Does the POTW use the Division’s model inspection form or equivalent? Yes No If no, does the POTW form include all Division data? Yes No 53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? Yes No If no, Explain. 54. What criteria are used to determine if a slug/spill control plan is needed? Potential of slugs or spills within the facility to reach the WWTP. 55. What criteria does the POTW use to deter mine if a submitted slug/spill control plan is adequate? Contacts, response and available spill control. 56. How does the POTW decide where the sample point for an SIU should be located? A representative location and accessibility to power 57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each ti me? (example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly) POTW: Yes No SIU: Yes No If yes, Explain. POTW and SIU periodically review sampling procedures. POTW will begin splitting samples as an additional verification step. 58. Who performs sample analysis for the POTW for Metals ETS Conventional Parameters ETS Organics ETS 59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples. SIU collects their samples utilizing bottles provided by ETS and ETS courier picks up samples. POTW also utilizes ETS chains of custody. Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA) 60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? YES NO 60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? YES NO 60c. Is LTMP/STMP Data Maintained in Table or Equivalent? YES NO Is Table Adequate? YES NO 60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? YES NO Division Inspector, verify yourself! 60e. If NO to any above, list violations _____________________________________________________________________ 60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? YES NO If yes, which ones? Eliminated: Added:________________________________ 61. Do you complete your own headworks analysis (HWA) ? Yes No If no, who completes your HWA? Phone ( ) -- 62. Do you have plans to revise your HWA in the near future? Yes No If yes, what is the reason for the revision? (mark all that apply) Increased average flow NPDES limits change More LTMP data available Resolve over allocation 5 year expiration Other Explain. May revise depending on any changes in next permit renewal and/or if issues with copper or chloride. DocuSign Envelope ID: 93FCA9D7-84A1-4B5C-A6BF-0DC063D3428B NC DWR Pretreatment Audit Form Revised: December 2016 Page 5 63. In general, what is the most limiting criteria of your HWA? Inhibition Pass Through Sludge Quality 64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? Yes No Explain. Town continues to look for additional application fields, so sludge does not become a limiting factor. Summary 65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No current changes. DocuSign Envelope ID: 93FCA9D7-84A1-4B5C-A6BF-0DC063D3428B NC DWR Pretreatment Audit Form Revised: December 2016 Page 6 INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION) 66. User Name 1. Tryon Finishing Corp. 2. 3. 67. IUP Number 001 68. Does File Contain Current Permit? Yes No Yes No Yes No 69. Permit Expiration Date 70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A N/A 71. Does File Contain Permit Application Completed Within One Year Prior to Permit Issue Date? Yes No Yes No Yes No 72. Does File Contain Inspection Completed Within Last Calendar Year? Yes No Yes No Yes No 73. a. Does File Contain 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 74. 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 75. a. Does File Contain Original Permit Review Letter from 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 76. During Most Recent Semi-Annual Period, Did POTW Complete its Sampling as Required by IUP, including Flow? Yes No Yes No Yes No 77. Does File Contain POTW Sampling Chain-Of-Custody Forms? Yes No Yes No Yes No 78. During Most Recent Semi-Annual Period, Did SIU Complete its Sampling as Required by IUP, including Flow? Yes No N/A Yes No N/A Yes No N/A 79. During Most Recent Semi-Annual Period, Did SIU submit all reports on time? Yes No N/A Yes No N/A Yes No N/A 80a. 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 80b. For categorical IUs with Production based limit s, does file include production rates and/or flows as Required by IUP? Yes No N/A Yes No N/A Yes No N/A 81. During Most Recent Semi-Annual Period, Did POTW Identify All Limits Non-Compliance from Both POTW and SIU Sampling? Yes No Yes No Yes No 82. During Most Recent Semi-Annual Period, Did POTW Identify All Reporting Non-Compliance from SIU Sampling? Yes No N/A Yes No N/A Yes No N/A 83. a. Was 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 and obtain results within 30 days of becoming aware of SIU limit violations in the POTW’s sampling of 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 84. During Most Recent Semi-Annual Period, Was SIU in SNC? Yes No Yes No Yes No 85. During Most Recent Semi-Annual Period, Was Enforcement Taken as Specified in POTW's ERP (NOVs, Penalties, timing, etc.)? Yes No N/A Yes No N/A Yes No N/A 86. Does File Contain Penalty Assessment Notices? Yes No N/A Yes No N/A Yes No N/A 87. Does File Contain Proof Of Penalty Collection? Yes No N/A Yes No N/A Yes No N/A 88. a. Does 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 89. Did POTW Representative Have Difficulty in Obtaining Any Requested Information For You? Yes No Yes No Yes No FILE REVIEW COMMENTS: All paperwork was readily available. An NOV was issued for a copper exceedance in the second half of 2021 and follow-up sample results were within compliance. See summary for additional details. DocuSign Envelope ID: 93FCA9D7-84A1-4B5C-A6BF-0DC063D3428B NC DWR Pretreatment Audit Form Revised: December 2016 Page 7 INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY N C 0 0 2 1 6 0 1 03 15 22 1. Industry Inspected: Tryon Finishing Corps 2. Industry Address: 250 Screvens Rd 3. Type of Industry/Product: Textile- Dye facility 4. Industry Contact: Naiden Kremenliev Title: President Phone: 828-237-6277 Fax: 864-616-7360 5. Does the POTW Use the Division Model Inspection Form or Equivalent? 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: Several items were discussed with the Town and Tryon Finishing. Tryon Finishing is working on SOPs for the pretreatment program so sampling is completed adequately. Town staff have also offered to help train/aid in sampling, so all parties are comfortable with the procedure. No major areas of concern for spills into the collection system. We discussed with Tryon Finishing changes may occur to the pretreatment permit in the future should the Town determine reduced copper and chloride levels are needed to maintain compliance with their NPDES Permit. Audit SUMMARY AND COMMENTS: Audit Comments: Overall, the program is being adequately run and staff are becoming more comfortable with the various aspects of the program. New permit limits may require future modifications depending o n plant performance during the rest of the permit cycle. Requirements: Recommendations: As a reminder, if the SIU has consistent permit IUP limits exceedances, increased enforcement action needs to be taken by Tryon in accordance with the ERP. Currently in the ERP, a compliance schedule/order is required if a facility is in SNC for two consecutive monitoring periods. Additionally, a compliance schedule is recommended should the Town’s effluent numbers indicate a need for reduction in copper and chloride. A schedule would give the SIU time to assess how best to reduce pollutants of concern in their waste stream. NOD: Yes No NOV: Yes No QNCR: Yes No POTW Rating: Satisfactory Marginal Unsatisfactory Audit COMPLETED BY: Mikal Willmer DATE: 03/22/2022 Mikal Willmer, Asheville Regional Office DocuSign Envelope ID: 93FCA9D7-84A1-4B5C-A6BF-0DC063D3428B