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Home My WebLink AboutNC0021601_NOV-2024-PC-0004_20240104 January 04, 2024 Jim Fatland Town of Tryon 301 N Trade St Tryon, NC 28782 SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2024-PC-0004 Permit No. NC0021601 Tryon WWTP Polk County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Tryon WWTP on December 19, 2023. 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 violation(s) were noted during the inspection: Inspection Area Description of Violation _________________________________________________________________________________________________________________________________________________________________________ Effluent Sampling Currently, effluent sampling is time-based. Per permit requirements (see Part II, Section A) sampling should be flow-proportional. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: 068AB960-2088-4A28-956F-BFF9CB0B63D2 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, please respond in writing to this office within 30 days upon your receipt of this Notice of Violation regarding your plans or measures to be taken to address the indicated violations and other identified issues, if applicable. If you should have any questions, please do not hesitate to contact Melanie Kemp with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500 or melanie.kemp@deq.nc.gov. Sincerely, Daniel J. Boss, Acting Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENT: Compliance Evaluation Inspection Report Ec: LF, Brad McKinney (ORC), Deborah Bradley (BORC) DocuSign Envelope ID: 068AB960-2088-4A28-956F-BFF9CB0B63D2 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 23/12/19 C S31112171819 20 21 66 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved------------------- 3 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 10:00AM 23/12/19 20/08/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Bradley Lynn McKinney/ORC// Other Facility Data 12:00PM 23/12/19 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 Facility Site Review 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 Melanie Kemp DWR/ARO WQ/ - - / 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: 068AB960-2088-4A28-956F-BFF9CB0B63D2 NPDES yr/mo/day 23/12/19 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Melanie Kemp, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Town of Tryon’ s WWTP on December 19, 2023, to ensure the facility is operating in compliance with NDPES permit NC0021601. Brad McKinney (ORC) and Deborah Bradley (BORC) were present and assisted with the inspection. Sampling: Effluent composite samples are currently time-based (collecting 100 mL/hour). Per permit requirements (see Part II, Section A), effluent composite samples should be flow-proportional. A notice of violation (NOV) is being issued for failure to comply with permit requirements. Mechanical Bar Screen: The bar screen is still operational, however, the facility reported that based on the age and parts availability of the equipment it should be replaced in the next couple of years. Secondary Clarifiers: The weir teeth on Clarifier # 1 are still severely rusted. This does not appear to have adversely affected effluent values, but this has been a noted deficiency since 2017. Funds required for clarifier upgrades should be included in the next town budget. During the inspection, a meeting was conducted with Tryon Finishing Corp to discuss copper limits and flow rates. Deborah Bradley (WWTP BORC), Melanie Kemp (ARO) and Naiden Kremenliev (President of Tryon Finishing Corp) were present during the meeting. The industrial user (IU) is discussing the addition of industrial hemp fiber processing in the coming years. The facility is interested in adjusting their permitted flow and copper limits. The current Headworks Analysis submitted by the town indicates that the WWTP has additional copper allocation that could be provided to the IU, should they want to change their permit. NC0021601 17 (Cont.) Page#2 DocuSign Envelope ID: 068AB960-2088-4A28-956F-BFF9CB0B63D2 Permit:NC0021601 Inspection Date:12/19/2023 Owner - Facility: Inspection Type: Tryon WWTP Compliance Evaluation 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? 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? Comment: Flow Measurement - Influent 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? Influent flow was reading at 0.224 MGD during the inspection. The flow meter was last calibrated on 12/8/23. 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? Currently, sampling is time-based (100 mL/hour).Comment: Bar Screens Yes No NA NE Type of bar screen Page#3 DocuSign Envelope ID: 068AB960-2088-4A28-956F-BFF9CB0B63D2 Permit:NC0021601 Inspection Date:12/19/2023 Owner - Facility: Inspection Type: Tryon WWTP Compliance Evaluation Bar Screens Yes No NA NE 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? Facility reports that the bar screen is dated and back-up parts are difficult to source. The bar screen should be upgraded in the coming years. 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) No observable sludge blanket present in Clarifier 2 during inspection. Weir teeth are eroded and need to be replaced on Clarifier 1. 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? Page#4 DocuSign Envelope ID: 068AB960-2088-4A28-956F-BFF9CB0B63D2 Permit:NC0021601 Inspection Date:12/19/2023 Owner - Facility: Inspection Type: Tryon WWTP Compliance Evaluation Disinfection-Gas Yes No NA NE If yes, then what is the EPA twelve digit ID Number? (1000-____-____) If yes, then when was the RMP last updated? Manual feed system for chlorine gas. Two cylinders were in use and four stored during the inspection. The feed system is inspected and maintained yearly by an outside contractor. 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? Are the tablets the proper size and type? Liquid chlorine is dripped into contact chamber.Comment: Are tablet de-chlorinators operational? Number of tubes in use? 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? Effluent flow meter calibrated annually (last on 12/8/23).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)? Currently, sampling is time-based (100 mL/hour). Per the permit, effluent composite sampling should be flow-proportional. Comment: Page#5 DocuSign Envelope ID: 068AB960-2088-4A28-956F-BFF9CB0B63D2 Permit:NC0021601 Inspection Date:12/19/2023 Owner - Facility: Inspection Type: Tryon WWTP Compliance Evaluation Effluent Sampling Yes No NA NE 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: Page#6 DocuSign Envelope ID: 068AB960-2088-4A28-956F-BFF9CB0B63D2