The URL can be used to link to this page

Home My WebLink AboutNC0021601_CEI_NOD2022PC0042_20220407 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED April 07, 2022 Zachary Ollis, Town Manager Email: manager@tryonnc.gov Town of Tryon SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2022-PC-0042 Permit No. NC0021601 Tryon WWTP Polk County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Tryon WWTP on March 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. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Asheville Regional Office. The following deficiency was noted during the inspection: Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________ Compliance Schedules An Action Plan was due no later than July 1 2021 as required by Section A.4 of the permit to address the new copper and chloride limits. The plan was not submitted until 2022. _________________________________________________________________________________________________________________________________________________________________________ In addition, the issues below must also be addressed: Compliance Issue: Clarifier #1: The weir teeth are rusted in clarifier #1 and in need of repair/replacement. This has not adversely affected treatment and the Asheville Regional Office acknowledges the Town has budgeted for the work in 2025; however, it is recommended these repairs occur sooner to avoid costly emergency repairs. DocuSign Envelope ID: 0E89F383-4465-446D-9F52-1CDED52BBA4E Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. To prevent further action, carefully review these deficiencies and address the causes of non-compliance to prevent the recurrence of similar situations. If you should have any questions, please do not hesitate to contact Mikal Willmer with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4686 or via email at mikal.willmer@ncdenr.gov. Sincerely, Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: LF Deborah Bradley, ORC DocuSign Envelope ID: 0E89F383-4465-446D-9F52-1CDED52BBA4E 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 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 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) Permit Flow Measurement Operations & Maintenance Records/Reports Self-Monitoring Program Sludge Handling Disposal Facility Site Review Compliance Schedules Effluent/Receiving Waters 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: 0E89F383-4465-446D-9F52-1CDED52BBA4E 4/7/2022 4/7/2022 NPDES yr/mo/day 22/03/15 Inspection Type C3111218 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 Compliance Evaluation Inspection of the Town of Tryon’s WWTP in conjunction with the facility’s Pretreatment Audit on 3/15/2022. Deborah Bradley (ORC) and Mike Fife (BORC) were present and assisted in the inspection. The facility is being operationally maintained in compliance with permit limits; however, there are items noted during the inspection that should be addressed. Copper & Chloride Compliance Schedule Section A (4): Tryon did not meet the first milestone due on July 1, 2021. The requirements for this and the next milestone were discussed with plant staff. The Town has drafted a response to milestones one and two and will submit to the Division by July 1, 2022. It should be noted, the Town has not exceeded the new limits listed in the permit that go into effect on July 1, 2023. Solids Handling: Facility holds a Class B permit for land application. The Town land applies their own residuals as needed. Tryon has a sludge thickener followed by a mixed sludge holding pond that is lime stabilized before land application. No issues maintaining solids within the facility. Mechanical Bar Screen: Screen is still in working order; however, the screen bypass flow channel during high flow events does not have a manual bar screen and can introduce debris into the aeration basin. Recommend Tryon explore installation of a manual screen for the bypass flow channel. Secondary Clarifiers: Clarifier #2 has been refurbished and Clarifier #1 has new electrical and drive; however, the weir teeth are still severely rusted. This does not appear to have adversely affected effluent values, but this has been a noted deficiency since 2017. This was discussed with the Town Manager after the facility inspection. Clarifier upgrades are budgeted in the CIP for 2025. Recommend allocating funds sooner in the CIP calendar to avoid an emergency repair. Disinfection: Facility manually adjusts chlorine gas during rain events. They check chlorine residuals before and after to determine the appropriate feed rate. Dedicated Field: Staff report the changing banks of Vaughn Creek are beginning to reduce the acreage of the dedicated land application field. Please confer with your contracted soil scientist about the severity of the loss. If significant acreage is being lost, a permit modification will be required to reduce the permitted acreage for this site. NC0021601 17 (Cont.) Page#2 DocuSign Envelope ID: 0E89F383-4465-446D-9F52-1CDED52BBA4E Permit:NC0021601 Inspection Date:03/15/2022 Owner - Facility: Inspection Type: Tryon WWTP Compliance Evaluation Compliance Schedules Yes No NA NE Is there a compliance schedule for this facility? Is the facility compliant with the permit and conditions for the review period? Facility missed a milestone. See summary for details.Comment: 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? Analyze DO, pH, setteable solids, MLSS, sludge judge.Comment: 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? Municipal special conditions.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? Page#3 DocuSign Envelope ID: 0E89F383-4465-446D-9F52-1CDED52BBA4E Permit:NC0021601 Inspection Date:03/15/2022 Owner - Facility: Inspection Type: Tryon WWTP Compliance Evaluation Record Keeping Yes No NA NE (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? Facility has copy of previous year's Annual Report on file for review? Reviewed annual report during inspection. Sent via mail to Central Office.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? New meter calibrated 12-10-2022 by Matt Lassiter.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 an aerobic digester. See summary for details.Comment: Solids Handling Equipment Yes No NA NE Is the equipment operational? Is the chemical feed equipment operational? Page#4 DocuSign Envelope ID: 0E89F383-4465-446D-9F52-1CDED52BBA4E Permit:NC0021601 Inspection Date:03/15/2022 Owner - Facility: Inspection Type: Tryon WWTP Compliance Evaluation Solids Handling Equipment Yes No NA NE 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? See summary for details.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? Is disposal of screening in compliance? Is the unit in good condition? This is an older mechanical screen and not rated for peak flows. See summary for details. 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) Clarifiers had 1' and 2' sludge blankets. See summary for details.Comment: Aeration Basins Yes No NA NE Page#5 DocuSign Envelope ID: 0E89F383-4465-446D-9F52-1CDED52BBA4E Permit:NC0021601 Inspection Date:03/15/2022 Owner - Facility: Inspection Type: Tryon WWTP Compliance Evaluation 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) Attempt to keep DOs below 3 mg/L throughout the year.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? Staff manually adjust chlorine feed. See summary for details.Comment: 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? Comment: Are the tablets the proper size and type? Are tablet de-chlorinators operational? Page#6 DocuSign Envelope ID: 0E89F383-4465-446D-9F52-1CDED52BBA4E Permit:NC0021601 Inspection Date:03/15/2022 Owner - Facility: Inspection Type: Tryon WWTP Compliance Evaluation De-chlorination Yes No NA NE Number of tubes in use? 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)? Is sampling performed according to the permit? Time composite. Sampler at 3 degrees during inspection.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: Page#7 DocuSign Envelope ID: 0E89F383-4465-446D-9F52-1CDED52BBA4E