NC0021601_Inspection_20180420

State of North Carolina | Environmental Quality | Water Resources
2090 U.S. Highway 70 Swannanoa, NC 28778
828 296 4500

April 20, 2018

Zach Ollis
Town Manager
Town of Tryon
301 N Trade St.
Tryon, NC 28782

SUBJECT: Pretreatment Compliance Inspection
Town of TryonWWTP
Permit No: NC0021601
PolkCounty

Dear Mr. Ollis:

Enclosed please find a copy of the Pretreatment Compliance Inspection conducted on March 8, 2018. The
pretreatment program was found to be in compliance with permit NC0021601 and applicable pretreatment
regulations.
The attached North Carolina Division of Water Resources Pretreatment Compliance Inspection (PCI)
Report lists any additional items of importance noted during the inspection.

The assistance provided by Ronnie Pack, Deborah Bradley and Christopher Cochran during the inspection
was greatly appreciated. Please refer to the enclosed inspection report for additional observations and
comments. If you or your staff have any questions, please call me at 828-296-4686 or Vivien Zhong at
[phone] [e-mail].

Sincerely,

Mikal Willmer, Environmental Specialist
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

Enc.: PCI

Ec: Ronnie Pack, ORC
WQS-ARO Server
PERCS-LF
20180328_NC0021601_PCI

DocuSign Envelope ID: 933148DE-0BC8-4275-9AB0-49501BBBDE36
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 18/03/08 P 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
09:30AM 18/03/08 16/06/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Other Facility Data
01:30PM 18/03/08 18/12/31
Name, Address of Responsible Official/Title/Phone and Fax Number
Deborah Bradley, /ORC/828-894-2048/Contacted
Yes
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 ARO WQ//828-296-4686/
Beverly Price Division of Water Quality//828-296-4500/
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: 933148DE-0BC8-4275-9AB0-49501BBBDE36
4/20/2018
4/20/2018
NPDES yr/mo/day
18/03/08
Inspection Type
P3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Inspectors Mikal Willmer and Beverly Price, with the Asheville Regional Office, conducted a
Pretreatment Compliance Inspection of the Town of Tryon's Pretreatment Program on March 8, 2018.
This inspection consisted of a file review of all program elements in relation to the SIU Carolina Yarn
Processors. The program was well maintained and appeared to be in compliance with all
requirements. Please refer to the Pretreatment Compliance Inspection Report for additional comments
or recommendations.
NC0021601 17
Page#2
DocuSign Envelope ID: 933148DE-0BC8-4275-9AB0-49501BBBDE36
Permit:NC0021601
Inspection Date:03/08/2018
Owner - Facility:
Inspection Type:
Tryon WWTP
Pretreatment Compliance
Yes No NA NE
Page#3
DocuSign Envelope ID: 933148DE-0BC8-4275-9AB0-49501BBBDE36
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT

BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Tryon
2. Control Authority Representative(s): Ronnie Pack,/Deborah Bradley/Christopher Cochran
3. Title(s): Pretreatment Coordinator/ORC/BORC
4. Last Inspection Date: 05/19/2016 Inspection Type (Check One): PCI Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? YES NO
6. Is POTW under an Order That Includes Pretreatment Conditions? YES NO
Order Type, Number, Parameters: _______________________________ Are Milestone Dates Being Met? YES NO

ICIS CODING
Main Program Permit Number MM/DD/YY
| N | C | 0 | 0 | 2 | 1 | 6 | 0 | 1 | | 03 | 08 | 18 |

7. Current Number Of Significant Industrial Users (SIUs)? 1
8. Number of SIUs With No IUP, or With an Expired IUP ? 0
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year? 0
10. Number of SIUs Not Sampled By POTW in the Last Calendar Year? 0
11. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual
Periods?
0
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods? 0
13. Number of SIUs in SNC with Pretreatment Schedule? 0
14. Number of SIUs on Schedules? 0
15. Current Number Of Categorical Industrial Users (CIUs)? 0
16. Number of CIUs in SNC? 0

POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations?
If Yes, What are the Parameters and How are these Problems Being Addressed?
YES NO

18. Since the Last PCI, has the POTW had any Problems Related to an Industrial
Discharge (Interference, Pass-Through, Blockage, Citizens’ Complaints, Increased
Sludge Production, Etc.)?
If Yes, How are these Problems Being Addressed?
YES NO
See Summary

19. Which Industries have been in SNC for Limits or Reporting during
either of the Last 2 Semi-Annual Periods? Not Been Published for
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
SNC for Limits:0
SNC for Reporting:0
Not Published:N/A
20. Which Industries are on Compliance Schedules or Orders? For all SIUs on an
Order, Has a Signed Copy of the Order been sent to the Division?

0

21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
YES NO

LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? YES NO
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? YES NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? YES NO Is Table Adequate? YES NO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? YES NO Inspector, please verify yourself!
26. If NO to 23 - 26, list violations _______________________________________________________________________________
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? YES NO
If yes, which ones? Eliminated: Added:_______________________

DocuSign Envelope ID: 933148DE-0BC8-4275-9AB0-49501BBBDE36
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2
28. PRETREATMENT PROGRAM ELEMENTS REVIEW- Please review POTW files, verify POTW has copy of Program Element
in their files, complete with supporting documents and copy of 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) 10/01/2013 Yes No 06/17/2014

Yes No 09/30/2018
Industrial Waste Survey (IWS) 05/01/2013 Yes No 08/08/2013 Yes No 05/01/2018
Sewer Use Ordinance (SUO) 1/22/2013 Yes No 4/02/2013 Yes No
Enforcement Response Plan (ERP) 6/24/2016 Yes No 9/07/2016 Yes No
Long Term Monitoring Plan (LTMP) 9/21/2015 Yes No 10/09/2015 Yes No
________________________________________________________________________________________________________________
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. Carolina Yarn Processors 2. 3.
30. IUP Number 001
31. Does File Contain Current Permit? Yes No Yes No Yes No
32. Permit Expiration Date 12/31/2021
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A N/A
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
Yes No Yes No Yes No
35. Does File Contain an Inspection Completed Within Last Calendar Year? Yes No Yes No Yes No
36. a. Does the File Contain a 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
37. 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
38. a. Does File Contain Original Permit Review Letter from the 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
39. During the Most Recent Semi-Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
Yes No Yes No Yes No
40. Does File Contain POTW Sampling Chain -Of-Custody Forms? Yes No Yes No Yes No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
Yes No N/A Yes No N/A Yes No N/A
41b. During the Most Recent Semi-Annual Period, Did SIU submit all reports
on time?
Yes No N/A Yes No N/A Yes No N/A
42a. 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
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
Yes No N/A Yes No N/A Yes No N/A
43a. During the Most Recent Semi-Annual Period, Did the POTW Identify
All Limits Non-Compliance from Both POTW and SIU Sampling?
Yes No Yes No Yes No
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non-Compliance from SIU Sampling?
Yes No N/A Yes No N/A Yes No N/A
44. a. Was the 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 within 30 days of becoming aware
of SIU limit violations in the POTW’s sampling of the 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
46. During the Most Recent Semi-Annual Period, Was the SIU in SNC? Yes No Yes No Yes No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
Yes No N/A Yes No N/A Yes No N/A
48. Does the File Contain Penalty Assessment Notices? Yes No N/A Yes No N/A Yes No N/A
49. Does The File Contain Proof Of Penalty Collect ion? Yes No N/A Yes No N/A Yes No N/A
50. a. Does the 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
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
Yes No Yes No Yes No

DocuSign Envelope ID: 933148DE-0BC8-4275-9AB0-49501BBBDE36
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3
FILE REVIEW COMMENTS:
5. Updated ERP has been submitted and approved.
18. ORC and Pretreatment Coordinator report no pass-through interferences; however, inspectors noted more than trace amounts of foam
in the discharge. The ORC and BORC stated they did not usually see that amount of foam in the discharge. If this continues, T ryon should
take steps, as needed, to mitigate foam in the discharge.
36. CYP created a written spill response plan. A copy is retained in the SIU’s file by the POTW.
43a. During the most recent semi-annual period, there was one limit violation identified from the POTW sampling. CYP’s routine quarterly
sampling approximately 30 days following the exceedance showed the facility was in compliance with their Zinc limit.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
| N | C | 0 | 0 | 2 | 1 | 6 | 0 | 1 | | 03 | 08 | 18 |

1. Industry Inspected: File review only. See comments below.
2. Industry Address: 250 Scrivens Rd, Tryon
3. Type of Industry/Product: Textiles-yarn and bandanas
4. Industry Contact: Ken Tucker Title: Director Phone: [phone]
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?
Reviewed POTW inspection conducted on 9/7/2017-inspection form contained all elements.
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:
File review only. A pretreatment audit was conducted in May of 2016 and an NPDES inspection of CYP was conducted in August 2016.
No reported issues related to CYP. CYP had one TSS limit violation of their NPDES permit in January 2018.

OVERALL SUMMARY AND COMMENTS:
Comments: Pretreatment Coordinator, Ronnie Pack, does an excellent job of maintaining and organizing all files. All program items were
readily available and easily accessible during the inspectio n.
Requirements: The POTW is aware of the 2018 due dates for the HWA and IWS.
Recommendations: Facility is well managed. Recommended monitoring the effluent for excessive discharge of foam and take steps as
needed if it appears to be a continuing occurrence and/or issue.
NOD: YES NO
NOV: YES NO
QNCR: YES NO
POTW Rating:
Satisfactory X Marginal UnSatisfactory
PCI COMPLETED BY: Mikal Willmer & Beverly Price -ARO DATE: 03/08/2018

DocuSign Envelope ID: 933148DE-0BC8-4275-9AB0-49501BBBDE36