NC0021601_NOD_20170417

5
Certified Mail # 7015 1520 0003 5463 4293
Return Receipt Requested
April 10, 2017
Zack 011is, Town Manager
Town of Tryon
301 N Trade St
Tryon, NC 28782
SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2017-PC-0144
Permit No. NCO021601
Tryon WWTP
Polk County
Dear Mr. 011is:
The North Carolina Division of Water Resources conducted an inspection of the Tryon WWTP on April 4, 2017.
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(s) was noted during the inspection:
Inspection Area Description of Deficiency
Secondary Clarifier The clarifier weirs are severely rusted and eroding away.
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.
Please respond in writing to this office within 30 days upon your receipt of this Notice of Deficiency regarding
your plans or measures to be taken to address the indicated deficiency. Please include a timeline for proposed
repairs.
State of North Carolina I Environmental Quality I Water Resources
2090 U.S. 70 Highway, Swannanoa, NC 28778
828-296-4500

/f
S •'
If you should have any questions,, please do not hesitate to contact Daniel Boss with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4500.
Sincerely,
114
G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS: Inspection Report
,j
Cc: Deborah Bradley, ORC
WQS Asheville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
G:\WR\WQ\Polk\Wastewater\Municipal\Tryon WWTP 21601\CEI.4.4.2017\NOD-2017-PC-0144.rtf

II
United Slates Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report =
Approval expires Bz31-98
Section A` National Data System" Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day, Inspection Type Inspector Fac Type
1 IN I 2 IS I 3 I NCO021601 L11. 12 17/o4/04 17 18 19 I ± I 201 I ,.
211 1 1 1 1 1 1 1 1 1.1 1 I I I I I I I I I I I I I L I I I I I I I I I I i l l l l l f6
Inspection
Work Days Facility Self -Monitoring Evaluation.Rating B1 QA — Reserved —
671
70 I I 71 I' I 72 I NJ 731 I 174 751 I. I I. I I I I80
LJ I
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
10:OOAM 17/04/04
16/06/01
Tryon WWTP
1526 E Howard St
Exit Time/Date
Permit Expiration Date
Tryon NC 28782
11:45AM, 17/04/04
18/12/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other. Facility Data
Deborah M Bradley/ORC/828-859-5626/
Name, Address of Responsible Official/Title/Phone and Fax Number
Deborah Bradley, /ORC/828-8942048! Contacted
Yes
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow.Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal N Facility Site Review Effluent/Receiving Waters
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary) 0
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Daniel J Boss j,(� �G — ARO WQH828-296-4658/
Signature of M.. yrta.gement Q A Reviewer Agency/Office/Phone and Fax Numbers Date
t✓4AG,l
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type (Cont.)
31 NC0021601 I1 12 17/04/04 17 18 ICI
Section D: Summary of Finding/Comments (Attach'additional sheets of narrative and checklists as necessary)
I, Dan Boss, conducted a Compliance Evaluation Inspection at the Tryon WWTP on 4/4/2017.
Deborah Bradley (ORC), Christopher Cochran, and Ronnie Pack guided me throughout the inspection.
Overall the WWTP appeared clean and functioning properly. Record keeping at Tryon appeared
complete and accurate.
The color of the mixed liquor was much blacker than is typical for a healthy activated sludge system.
Deborah explained that the reason for that is the Carolina Yarn Processors Plant contributes ink to the
influent flow.
I tested a grab sample of the effluent for chlorine residual. The result was 41 ug/L which is compliant
with the permit.
The permit lists an aerobic digester as one of the components of this facility. Deborah said that they
do not have an aerobic digester, but the sludge holding tank for wasted sludge used to have a source
of air. There is also a sludge lagoon on site which is used to store and prepare sludge for land
application purposes and is not listed in the permit. Upon the next renewal of the permit, the listed
components of the facility should be changed to reflect the current facility:
The one maintenance issue that needs to be addressed is that, the clarifier weirs are severely rusted
and are beginning to erode away in places. The rusting is not affecting the quality of the clarifier
effluent yet and doesn't seem to be causing short circuiting. If this issue isn't dealt with though,
eventually the weir will fail and emergency repairs will be needed and effluent violations could result.
Page#

if
Permit: NCO021601 Owner - Facility: Tryon WNliP
Inspection Date: 04/04/2017 Inspection Type: Compliance Evaluation
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). ,Has the permittee submitted a new
1:1
❑
-a
❑
application?
Is the facility as described. in the. permit?
❑
®
❑
❑
# Are there any special conditions for the permit?
❑
M
❑
❑
Is access to the plant site restricted to the general public?
0
❑
❑
❑
.Is the inspector granted access to all areas for inspection?
M
❑
❑
❑
Comment: Permit -describes an aerobic digester which does not exist and omits an existing
sludge
lagoon
Record Keeping
Yes No NA NE
Are'records kept and maintained as required by the permit?
M
❑
❑
❑
Is all required information readily available, complete and current?
M
❑
❑
❑
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?
0
❑
❑
❑
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?
0
❑
❑
❑
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
❑
❑
0
❑
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?
0
❑
❑
❑
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?
0
❑
❑
❑
Facility.has copy of previous year's Annual Report'on file for review?
M
❑
❑
❑
Comment:
Operations '& Maintenance , Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ❑0 ❑ ❑
Page# 3

IV
Permit: NCO021601 Owner - Facility: Tryon WWTP
Inspection Date: 04/04/2017 Inspection Type: Compliance Evaluation
Operations & Maintenance Yes 'No NA NE
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable' N ❑ ❑ ❑ ,
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: The clarifier weirs are severely rusted and beginning to erode away in places.
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?
N
❑
❑
❑
Is disposal of screening in compliance?
N
❑
❑
❑
Is the unit in'good condition?
0
❑
❑
❑
Comment:
Flow Measurement - Influent
Yes No NA NE
# Is flow meter used for reporting?
E
❑
❑
❑
Is flow meter calibrated annually?
❑
❑
❑
Is the flow meter operational?
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
N
❑
❑
❑
Comment:
Aeration Basins
Yes No NA NE
Mode of operation
Ext. Air
Type of aeration system
Surface
Is the basin free of dead spots?
0 ❑
❑
❑
Are surface aerators and mixers operational?
0 ❑
❑
❑
Aye the diffusers operational?
❑ ❑
E
❑
Is the foam the proper color for the treatment process?
❑ N
❑
❑
Does the foam cover less than 25% of the basin's surface?
E ❑
❑
❑
Is the DO level acceptable?
E ❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
❑
❑
❑
Comment: The color of the mixed liquor was much blacker than is typical for a healthy activated sludge
system. The reason is that the yarn processing plant contributes ink to the flow.
Page# 4

Permit: NC0021601 Owner - Facility: Tryon VNNTP
Inspection Date: 04/04/2017 Inspection Type: Compliance Evaluation
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?
A
❑
❑
❑
Are weirs level? -
0
❑
❑
❑
Is the site free of weir blockage?
0
❑
❑
.❑
Is the site free of evidence of short-circuiting?
M
❑
❑
❑
Is scum removal adequate?
M
❑
❑
❑
Is the site free of excessive floating sludge?
M
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the return rate acceptable (low turbulence)?
®
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
0
❑
❑
'❑
Is the sludge blanket level acceptable? (Approximately '/< of the sidewall depth)
❑
❑
❑
Comment:
Pumps-RAS-WAS
Yes No NA NE
Are pumps in place?
M' ❑
❑
❑
Are pumps operational?
❑
.❑
❑
Are there adequate spare parts and supplies on site?
❑ M
❑
❑
Comment: Pumps are not repaired on site and so they don't keep spare
parts on hand. They run. the
RAS on one pump only while a pump is being repaired.
Lagoons
Type of lagoons?
# Number of lagoons in operation at time of visit?
Are lagoons operated'in?
# Is a re -circulation line present?
Is lagoon free of excessive floating materials? ' .
# Are baffles between ponds or effluent baffles adjustable?
Are dike slopes clear of woody vegetation?
Are weeds controlled around the edge of the lagoonT
Are dikes free of seepage?
Are dikes free of erosion?
Are dikes free of burrowing animals?
# Has the sludge blanket in the lagoon (s) been measured periodically in multiple
locations?
Yes No NA NE
Facultative
M
❑
❑
❑
❑
❑
■
❑
❑
❑
❑
0
❑
❑
El
■
❑
❑
❑
■
❑
❑
❑
❑
❑
❑
■
❑
❑
❑
❑
❑
❑
Page# 5

Permit: NCO021601 Owner -Facility:. TryonWWTP
Inspection Date: 04/04/2017 Inspection Type: Compliance Evaluation
Lagoons
Yes No NA NE
# If excessive algae is present, has barley straw been used to help control the growth?
❑
❑
N
❑
Is the lagoon surface. free of weeds?
91
❑
❑
❑
Is the lagoon free of short circuiting?
N
❑
❑
❑
Comment: Lagoon has a mixer which is typically run before the sludge is land applied.
Disinfection -Gas
Yes No NA NE
Are cylinders secured adequately?
0
❑
❑
❑
Are cylinders protected from direct sunlight?
®
❑
❑
❑
Is there adequate reserve supply of disinfectant?
®
❑
❑
❑
Is the level of chlorine residual acceptable?
0
❑
❑
❑
Is the contact chamber free of growth, or sludge buildup?
0
❑
❑
❑
Is there chlorine residual prior to de -chlorination?
E
❑
❑
❑
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
❑
■
❑
❑
If yes, then is there a Risk Management Plan on site?
❑N
❑
❑
If yes, then what is the EPA twelve digit ID Number? (1000-
If yes, then when was the RMP last updated?
Comment: Chlorine residual was measured at 41 uq/L on site.
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?
E
❑
❑
❑
Are the tablets the proper size and type?
❑
❑
E
❑
Comment: Both chlorination and dechlorination have flow proportional feeds.
Are tablet de -chlorinators operational?
❑
❑
❑
Number of tubes in use?
Comment:
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
❑
E
❑
❑
Is flow meter calibrated annually?
0
❑
❑
❑
Is the flow meter operational?
0
❑
❑
❑
Page# 6

rf
Permit: NC0021601 Owner - Facility: Tryon WWfP
Inspection Date: 04/04/2017 Inspection Type: Compliance Evaluation
Flow Measurement - Effluent Yes No NA NE
(If units are separated) Does the chart recorder match the flow meter? ❑ ❑ ® ❑
Comment:
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
M
❑
❑
❑
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;
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
0
❑
❑
Is sample collected below all treatment units?
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
N
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
M,
❑
❑
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
0
❑
❑
❑
representative)?
Comment: At the time of inspection
Collected for composite.
them to 100 ml volumes.
Standby Power
Yes No NA NE
Is automatically activated standby power available?
0
❑
❑
❑
Is the generator tested by interrupting, primary power source?
0
❑
❑
❑
Is the generator tested under load?
SO
❑
❑
Was generator tested & operational during the inspection?
❑
❑
❑
M
Do the generator(s) have adequate capacity to operate the entire wastewater site?
i
❑
❑
: ❑
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
0
❑
❑
❑
Is the generator fuel level monitored?
0
❑
❑
❑
Comment: Deborah is going to call the fuel vendor to the check the extent of their fuel agreement.
Page# 7