NC0028916_NOV-2022-LV-0928_20230113

MAYOR
CRAIG JONES
MAYOR PRO-TEM
BRUCE HAMILTON
COMMISSIONERS
KAYREN BRANTLEY
ANGELA ELKINS
WALLACE JONES
DAMON PRINCE
NORTH
CAROLINA
TOWN MANAGER
GREG ZEPHIR
TOWN CLERK
CATHY MANESS
ATTORNEY
RUSSELL J. HOLLERS,III
January 13, 2023
Mark Brantley, Assistant Regional Supervisor
Water Quality Regional Operations
Section Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville, NC 23001-5905
RE: Notice of Violation, NOV — 2022-LV-0928
Troy WWTP
NPDES WW Permit No.
NC0028916 Montgomery County
RECEIVED
JAN 2 6 2023
DEQ-FAYETTEVILLE RE®IONAL OFFICE
Dear Mr. Brantley:
Please accept this letter as the Town of Troy's response to your letter received in
this office on January 8, 2023, regarding the three (3) violations detailed in NOV-
2022-LV-0928.
The Notice of Violation detailed in NOV 2022-LV-0928 pertained to value limits of
"BOD — 5-day Concentration" and "Nitrogen, Ammonia Total" exceeding the
Weekly Average. These two (2) levels being exceeded also led to the third
violation of the "Nitrogen, Ammonia" Monthly Average being exceeded. The
causes of these violations were not due to a failure in plant operation, but rather
an issue caused by one of the town's larger industries as a result of a power
failure during Hurricane Ian.
the week of October 1, 2022, one of the towns SIU's lost power for an extended
amount of time due to Hurricane Ian. The company, because of the loss of power
and the production of a product that could not be used, decided to empty the
product and discharge it to the collection system without normal pretreatment.
As a result of that decision approximately 4,000 gallons of high strength
wastewater were discharged to the collection system. This discharge
overwhelmed the treatment plant with high levels of BOD and TSS that affected
the treatment process. The plant's ORC immediately initiated a process of
wasting some of the solids from the plant to minimize the effects of the high
strength wastewater. Unfortunately, it took longer than expected for the treatment
TROY.NC.US I 315 N MAIN STREET I TROY, NC 27371 I 910-572-3661
THE TOWN OF TROY IS AN EQUAL OPPORTUNITY PROVIDER AND EMPLOYER.

plant to recover from the discharged slug, thereby causing the permitted limits for
BOD and NH3 to be exceeded.
The SIU was issued an NOV with penalty from the town for the slug load that led
to this NOV.
As I have alluded to in previous correspondences with you and your office in the
past, the town has the highest respect for the mandates and the requirements
that are associated with operating this facility and have taken great strides to
ensure that we have as well as maintained system as possible and are confident
that we have the best people in place to assure that the facility is operating at the
highest levels. While the operations of the town's wastewater facility are of the
highest importance, there are times when acts of nature contribute to some
errors and issues, such as the one described in this letter. The town's ORC
acted immediately to reduce the impact of the plant and any potential discharge
issues. In addition, the town acted expeditiously in notifying the SIU of the
problem and non-compliance along with issuing the appropriate NOV and
subsequent fine.
I hope that you will take these facts into consideration when determining any
further action against the Town of Troy and its wastewater facilities. If I can be of
any further assistance or there is additional information that is required, please
do not hesitate to call on me at 910.572.3661.
With Regards,
Greg Zephir
Town Manager