WQCS00111_NOV-2018-PC-0117_20180406

DocuSign Envelope ID: 23EE5395-E168-497A-A149-862F52CB673E
WarerResources
ENVLG0KME4rAi QUAL ITY
Certified Mail #7009 1680 0000 7515 6135
Return Receipt Requested
April 06, 2018
Zack 011is, Town Manager
Town of Tryon
301 N Trade St
Tryon, NC 28782
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2018-PC-0117
Permit No. WQCS00111
Tryon Collection System
Polk County
Dear Mr. 011is:
ROY COOPER
Grn m -,r
MICHAEL S. REGAIN
Secret
LT -NMA CUL PEPPER
-Inlerem Dlrecia?
The North Carolina Division of Water Resources conducted an inspection of the Tryon Collection System on
March 8, 2018. This inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in Collection System Permit No. WQCS00111. A summary of the findings and
comments noted during the inspection are provided in the enclosed copy of the inspection report.
The Collection System 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
Inspections Citizen complaints are logged at Town Hall and relayed to the collection system personnel.
Permit Condition 11.2 requires the Permittee to develop and adhere to a schedule for
reviewing complaint logs.
Permit Condition 111.2. requires the Permittee to maintain adequate records pertaining to
complaints for a minimum of three years.
Inspections Inspections of high priority lines are not documented.
Permit Condition VA. requires inspections of all high priority lines at least once per every
6 months.
Permit Condition III. 1. requires records to document compliance with Condition
VA.
State of North Carolina I Environmental Quality I Water Resources
2090 U.S. 70 Highway, Swannanoa, NC 28778
828-296-4500

DocuSign Envelope ID: 23EE5395-E168-497A-A149-862F52CB673E
Performance Standards The CIP covers the next twenty years and projects are listed in order of priority, it does not
include a 3-5 year period. This was noted in the last inspection.
Permit Condition I.6. the Permittee shall adopt and implement a Capital Improvement Plan
(CIP) to designate funding for reinvestment into the wastewater collection system
infrastructure. The CIP should address short-term needs and long-term "master plan"
concepts. The CIP should typically cover a 3-5 year period and include a description of the
project area, description of the existing facilities, known deficiencies and forecasted future
needs.
Records The systemwide map does not include pipe size, pipe material, approximate age and number
of service taps. This was noted in the last inspection.
Permit Condition III.3. requires the permittee to maintain an up-to-date map, accurate,
comprehensive map of its wastewater collection system that also notes the locations where
other wastewater collection systems become tributary. The map shall include: pipe size, pipe
material, pipe location flow direction, approximate pipe age, number of service taps.
Operation & Maintenance The Spill Control Plan does not include response time. This was noted in the last inspection.
Permit Condition II.9.b. requires adequate measures be taken to contain
and properly dispose of materials associated with SSOs. The permittee shall maintain a
Response Action Plan that addresses the following minimum items: a. contact phone numbers
for 24-hour response; b. response time; c. equipment list and spare parts inventory; d. access
to cleaning equipment; e. access to construction crews, contractors or engineers; f. sources of
emergency funds; site sanitation and cleanup materials; h. post-SSO assessment.
In addition, the issues below must also be addressed:
Compliance Issue(s):
1. Gary Walker is listed as the Backup ORC but the Division database shows that his certification is invalid.
Please determine if the certification is valid and if not, a certified Backup ORC should be designated.
2. There were three SSO's at the manholes on Braewick Road and Melrose Ave. Ext. between December 5, 2017
and February 19, 2018. All three SSO's reached surface waters. According to facility staff, the problem is
associated with the Town's Water Treatment Plant alum pond. The pond appears to be close to capacity.
The pond discharge contains debris that causes clogged lines and ultimately SSO's. The Town should make
resolving this issue a high priority.
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.
State of North Carolina I Environmental Quality I Water Resources
2090 U.S. 70 Highway, Swannanoa, NC 28778
828-296-4500

DocuSign Envelope ID: 23EE5395-E168-497A-A149-862F52CB673E
If you should have any questions, please do not hesitate to contact Beverly Price with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4500.
Sincerely,
DocuSigned by:
1 -r(KA f�6KA
082131105A3CA418...
On behalf of
G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS: Inspection Report
EC: WQS ARO Server
PERCS - LF
20180406_WQCS00111_NOV2018PC0117. rtf
State of North Carolina I Environmental Quality I Water Resources
2090 U.S. 70 Highway, Swannanoa, NC 28778
828-296-4500

DocuSign Envelope ID: 23EE5395-E168-497A-A149-862F52CB673E
Compliance Inspection Report
Permit: WQCS00111 Effective: 04/01/17 Expiration: 03/31/25 owner: Town of Tryon
SOC: Effective: Expiration: Facility: Tryon Collection System
County: Polk 423 N Trade St
Region: Asheville
Tryon NC 28782
Contact Person: Andrew McCallister Title: ORC Phone: [phone]
Directions to Facility:
System Classifications: CS2,
Primary ORC: Andrew Lee McCallister Certification: 995172 Phone: [phone]
Secondary ORC(s):
Gary Walker 13666 828-859-6654
On -Site Representative(s):
24 hour contact name Andrew Lee McCallister 828-859-6880
On-site representative Deborah M Bradley 828-859-5626
Related Permits:
NC0021601 Town of Tryon - Tryon WWTP
Inspection Date: 03/08/2018 psEntry Time: 09:20AM Exit Time: 01:OOPM
Primary Inspector: Beverly Price Q % Phone: [phone]
Secondary Inspector(s):
Mikal Willmer °j�
Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling
Permit Inspection Type: Collection system management and operation
Facility Status: Compliant Not Compliant
Question Areas:
Miscellaneous Questions Performance Standards Operation & Maint Reqmts
Records Monitoring & Rpting Reqmts Inspections
Manhole
(See attachment summary)
Page: 1

DocuSign Envelope ID: 23EE5395-E168-497A-A149-862F52CB673E
Permit: WQCS00111 Owner - Facility: Town of Tryon
Inspection Date: 03/08/2018 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
The Collection System inspection was conducted by Beverly Price and Mikal Willmer of the Asheville Regional Office.
Andrew McCallister and Deborah Bradley assisted with the inspection.
The collection system consists of approximately 19 miles of gravity sewer; no pump stations. The system includes pvc,
clay and ductile iron pipe. According to a map generated in 2005 by CAVANAUGH, there are 392 manholes.
Overall the collection system is fairly well maintained given that there are currently only two employees for the entire
system. The Town would benefit from an additional position to assist with collection system inspections and maintenance.
The following items were determined to be non-compliant during the inspection:
1.Citizen complaint records are not maintained. See Permit Condition 111.2. & 11.2.
2.Response time should be added to the Spill Control Plan. See Permit Condition 11.9.b.
3.Inspections of high priority lines are not documented. See Permit Condition VA.
4.The map needs to be updated to include pipe size, pipe material, approximate age and the number of service taps. See
Permit Condition 111.3.
5.The Capital Improvement Plan should include a three -five year period. See Permit Condition 1.6.
The following additional items should be addressed:
1.Gary Walker is listed as the Backup ORC but the Division database shows that his certification is invalid. Please
determine if the certification is valid and if not, a certified Backup ORC should be designated.
2.There were three SSO's at the manholes on Braewick Road and Melrose Ave. Ext. between December 5, 2017 and
February 19, 2018. According to facility staff, the problem is associated with the Town's Water Treatment Plant alum pond.
The pond appears to be close to capacity. The pond discharge contains debris which clogs lines and results in SSO's. The
Town should make this a high priority.
Page: 2

DocuSign Envelope ID: 23EE5395-E168-497A-A149-862F52CB673E
Permit: WQCS00111 Owner - Facility: Town of Tryon
Inspection Date: 03/08/2018 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Performance Standards Yes No NA NE
Is Public Education Program for grease established and documented? 0 ❑ ❑ ❑
What educational tools are used?
The Town of Tryon website.
The Upstate Newspaper - twice per year.
The Tryon Daily Bulletin.
Is Sewer Use Ordinance/Legal Authority available? 0 ❑ ❑ ❑
Does it appear that the Sewer Use Ordinance is enforced? ❑ ❑ ❑
Is Grease Trap Ordinance available? ❑ ❑ ❑
Is Septic Tank Ordinance available (as applicable, i.e. annexation) ❑ ❑ ❑
List enforcement actions by permittee, if any, in the last 12 months
Has an acceptable Capital Improvement Plan (CIP) been implemented?
❑
❑ ❑
Does CIP address short term needs and long term \"master plan\" concepts?
❑ ❑ ❑
Does CIP cover three to five year period?
❑
❑ ❑
Does CIP include Goal Statement?
❑ ❑ ❑
Does CIP include description of project area?
❑ ❑ ❑
Does CIP include description of existing facilities?
❑ ❑ ❑
Does CIP include known deficiencies?
❑ ❑ ❑
Does CIP include forecasted future needs?
❑ ❑ ❑
Is CIP designated only for wastewater collection and treatment?
❑
❑ ❑
Approximate capital improvement budget for collection system?
Total annual revenue for wastewater collection and treatment?
CIP Comments
The CIP covers the next twenty years and projects are listed in order of priority; it is not specific for the next 3-5
year period - this was noted in the last inspection.
The Water & Sewer budget for FY 2017-2018 is $1,617,813.
Is system free of known points of bypass?
❑ ❑ ❑
If no, describe type of bypass and location
Is a 24-hour notification sign posted at ALL pump stations?
❑
❑ 0 ❑
# Does the sign include:
Instructions for notification?
❑
❑ 0 ❑
Pump station identifier?
❑
❑ 0 ❑
24-hour contact numbers
❑
❑ 0 ❑
If no, list deficient pump stations
# Do ALL pump stations have an "auto polling" feature/SCADA?
❑
❑ 0 ❑
Number of pump stations
Number of pump stations that have SCADA
Page: 3

DocuSign Envelope ID: 23EE5395-E168-497A-A149-862F52CB673E
Permit: WQCS00111 Owner - Facility: Town of Tryon
Inspection Date: 03/08/2018 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Number of pump stations that have simple telemetry
Number of pump stations that have only audible and visual alarms
Number of pump stations that do not meet permit requirements
# Does the permittee have a root control program? ❑ ❑ ❑
# If yes, date implemented?
Describe:
The root control program was implemented approximately 12 years ago; solvents and root cutters are used.
Comment: The CIP includes water system infrastructure.
Inspections
Yes No NA NE
Are maintenance records for sewer lines available?
❑ ❑ ❑
Are records available that document pump station inspections?
❑
❑ ❑
Are SCADA or telemetry equipped pump stations inspected at least once a week?
❑
❑ ❑
Are non-SCADA/telemetry equipped pump stations inspected every day?
❑
❑ ❑
Are records available that document citizen complaints?
❑
❑ ❑
# Do you have a system to conduct an annual observation of entire system?
❑
❑ ❑
# Has there been an observation of remote areas in the last year?
❑
❑ ❑
Are records available that document inspections of high-priority lines?
❑
❑ ❑
Has there been visual inspections of high-priority lines in last six months?
❑ ❑ ❑
Comment: Citizen complaints are loaaed at Town Hall and relaved to the collection system Dersonnel.
Citizen complaints should be logged and available for review.
15,495' sewer lines were cleaned & replaced in 2017.
Inspections of high priority lines are required and should be documented.
There are currently only 2 collection system employees which makes proper maintenance of the
entire system difficult.
Operation & Maintenance Requirements
Are all log books available?
Does supervisor review all log books on a regular basis?
Does the supervisor have plans to address documented short-term problem areas?
What is the schedule for reviewing inspection, maintenance, & operations logs and problem areas?
Reviews are ongoing - problem areas are addressed as they arise.
Are maintenance records for equipment available?
Is a schedule maintained for testing emergency/standby equipment?
What is the schedule for testing emergency/standby equipment?
Do pump station logs include:
Inside and outside cleaning and debris removal?
Inspecting and exercising all valves?
Yes No NA NE
❑■❑❑
❑❑■❑
There are no pump
stations in this
system so there
are no backup
generators.
❑❑0❑
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DocuSign Envelope ID: 23EE5395-E168-497A-A149-862F52CB673E
Permit: WQCS00111 Owner - Facility: Town of Tryon
Inspection Date: 03/08/2018 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspecting and lubricating pumps and other equipment? ❑ ❑ 0 ❑
Inspecting alarms, telemetry and auxiliary equipment? ❑ ❑ ❑
Is there at least one spare pump for each pump station w/o pump reliability? ❑ ❑ ❑
Are maintenance records for right-of-ways available? ❑ ❑ ❑
Are right-of-ways currently accessible in the event of an emergency? ❑ ❑ ❑
Are system cleaning records available? ❑ ❑ ❑
Has at least 10% of system been cleaned annually? ❑ ❑ ❑
What areas are scheduled for cleaning in the next 12 months?
Is a Spill Response Action Plan available? 0 ❑ ❑ ❑
Does the plan include:
24-hour contact numbers
0
❑ ❑ ❑
Response time
❑
❑ ❑
Equipment list and spare parts inventory
❑ ❑ ❑
Access to cleaning equipment
❑ ❑ ❑
Access to construction crews, contractors, and/or engineers
❑
❑ ❑ ❑
Source of emergency funds
❑
❑ ❑ ❑
Site sanitation and cleanup materials
❑
❑ ❑ ❑
Post-overflow/spill assessment
❑ ❑ ❑
Is a Spill Response Action Plan available for all personnel?
❑ ❑ ❑
Is the spare parts inventory adequate?
0
❑ ❑ ❑
Comment: The response time should be added to the Spill Response Plan: this was noted in the last
inspection.
Records Yes No NA NE
Are adequate records of all SSOs, spills and complaints available? ❑ ❑ ❑
Are records of SSOs that are under the reportable threshold available? ❑ ❑ ❑
Do spill records indicate repeated overflows (2 or more in 12 months) at same location? ❑ ❑ ❑
If yes, is there a corrective action plan? ❑ ❑ ❑
Is a map of the system available? ❑ ❑ ❑
Does the map include:
Pipe sizes
❑
0 ❑ ❑
Pipe materials
❑
❑ ❑
Pipe location
❑ ❑ ❑
Flow direction
❑ ❑ ❑
Approximate pipe age
❑
❑ ❑
Number of service taps
❑
❑ ❑
Pump stations and capacity
❑
❑ ❑
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DocuSign Envelope ID: 23EE5395-E168-497A-A149-862F52CB673E
Permit: WQCS00111 Owner - Facility: Town of Tryon
Inspection Date: 03/08/2018 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
If no, what percent is complete?
List any modifications and extensions that need to be added to the map
The map needs to be updated to include the following: pipe size, pipe material, approximate age and the
number of service taps - this was noted in the last inspection.
# Does the permittee have a copy of their permit? 0 ❑ ❑ ❑
Comment: There have been 3 SSO's between 12/5/17 and 2/19/18 at Braewick Rd and Melrose Ext.; all
involved discharges to surface waters. The SSO's appear to be related to the Water Treatment
Plant alum pond backwash system.
Monitoring and Reporting Requirements Yes No NA NE
Are copies of required press releases and distribution lists available? ❑ ❑ ❑
Are public notices and proof of publication available? ❑ ❑ ❑
# Is an annual report being prepared in accordance with G.S. 143-215.1 C? ❑ ❑ ❑
# Is permittee compliant with all compliance schedules in the permits? ❑ ❑ 0 ❑
If no, which one(s)?
Comment:
PACKARD WOODWORKS -
Manhole
Yes No NA NE
Is manhole accessible?
0
❑ ❑ ❑
# Is manhole cover/vent above grade?
❑
❑ ❑
Is the manhole free of visible signs of overflow?
❑ ❑ ❑
Is the manhole free of sinkholes and depressions?
❑
❑ ❑
Is manhole cover present?
❑ ❑ ❑
# Is manhole properly seated?
❑ ❑ ❑
# Is manhole in good condition?
❑ ❑ ❑
# Is invert in good condition?
❑ ❑ ❑
Is line free-flowing and unrestricted in manhole?
❑ ❑ ❑
Is manhole free of excessive amounts of grease?
❑ ❑ ❑
Is manhole free of excessive roots?
❑ ❑ ❑
Is manhole free of excessive sand?
❑ ❑ ❑
Is manhole's extended vent screened?
❑
❑ ❑
Are vents free of submergence?
❑
❑ ❑
Are manholes free of bypass structures or pipes?
0
❑ ❑ ❑
Comment: There is a minor depression/eroded area on the northeast side of the manhole.
10 - Braewick Rd & Melrose
Manhole Yes No NA NE
Is manhole accessible? 0 1:11:1 ❑
# Is manhole cover/vent above grade? ❑ 0 ❑ ❑
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DocuSign Envelope ID: 23EE5395-E168-497A-A149-862F52CB673E
Permit: WQCS00111 Owner - Facility: Town of Tryon
Inspection Date: 03/08/2018 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Is the manhole free of visible signs of overflow?
❑ ❑ ❑
Is the manhole free of sinkholes and depressions?
❑ ❑ ❑
Is manhole cover present?
❑ ❑ ❑
# Is manhole properly seated?
❑ ❑ ❑
# Is manhole in good condition?
❑ ❑ ❑
# Is invert in good condition?
❑ ❑ ❑
Is line free-flowing and unrestricted in manhole?
❑ ❑ ❑
Is manhole free of excessive amounts of grease?
❑ ❑ ❑
Is manhole free of excessive roots?
❑ ❑ ❑
Is manhole free of excessive sand?
❑ ❑ ❑
Is manhole's extended vent screened?
❑
❑ ❑
Are vents free of submergence?
❑
❑ ❑
Are manholes free of bypass structures or pipes?
0
❑ ❑ ❑
Comment: This MH receives flow from the water treatment plant alum pond. The alum pond appears
to be
the main cause of recent overflows at both this MH and MH#11 located at Braewick Rd Right of
Way.
Page: 7