NC0028916_Notice of Violation and Pretreatment Performance Compliance Inspection_20230829

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
Certified Mail # 7022 2410 0003 3233 6608
Return Receipt Requested
August 29, 2023
M. Bryan Bowles
Town of Troy
315 N Main St
Troy, NC 27371
SUBJECT: NOTICE OF VIOLATION, NOV-2023-PC-0459
Pretreatment Performance Compliance Inspection
Troy WWTP
NPDES Permit No. NCO028916
Montgomery County
Dear Mr. Bowles:
A Pretreatment Performance Compliance Inspection of Troy's Pretreatment Program was
conducted by Sharon Moran from this office on August 3rd, 2023. The purpose of this
inspection is to determine the effectiveness of the pretreatment program by reviewing various
aspects of the program, which included files and records, industrial user inspections and
monitoring data, data management procedures and adherence to the Enforcement Response
Plan.
Enclosed, please find a copy of the Pretreatment Compliance Inspection Form.
The Town of Troy WWTP is currently a 1.2 MGD permitted facility and has two (2) Significant
Industrial Users; Republic Services dba. Uwharrie Environmental, and Saputo Cheese.
Two permit files were reviewed: Republic Services dba. Uwharrie Environmental, and Saputo
Cheese. A site visit was not conducted during this inspection.
This Pretreatment Compliance Inspection report indicated that the Town of Troy's Pretreatment
Program did not meet all reporting requirements as outlined in 40 CFR 122.41(I)(4).
The findings and comments noted during this inspection are provided in the enclosed copy of
the inspection report. Please respond in writing to this office within 30 days of your receipt of
this letter regarding your plans or measures to be taken to address the following issues:
The Town of Troy has not been sampling for Oil and Grease at the approved frequency.
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
Fayetteville Regional Office 1 225 Green Street I Suite 714 1 Fayetteville, North Carolina 28301
NORTH CAROLINA -
oeuaMemofEnvi—memaiauai\ 910.433.3300

The slug control and spill plan's signatures were past the integral year expiration for
contact update and re-signing.
Files maintained by the WWTP did not contain the most recent enforcement and proof
of penalty collection notices.
Thank you for your continued support of the North Carolina Pretreatment Program. If you
should have any questions, please contact Sharon Moran at [phone] or at
[e-mail].
Sincerely,
DocuSigned by:: ,V•&I
I
E4E1A9691DB248E...
Mark Brantley, Assistant Regional Supervisor
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
Cc: Upload to Laserfiche
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
!� Fayetteville Regional Office 1 225 Green Street I Suite 714 1 Fayetteville, North Carolina 28301
NORTH Cno OLINn
Department tenvironmentaiQuaii� /`� 910.433.3300

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
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 IN 1 2 u 3 I NC0028916 I11 121 23/08/03 I17 18I D I 19 I s I 201
21111I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
I 72 I ni I 71 I 74 79 I I I I I I I80
701� I 711 LL -1 I I
LJ
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)
09:30AM 23/08/03
21/02/01
Troy WWTP
650 Glen Rd
Exit Time/Date
Permit Expiration Date
Troy NC 27371
01:OOPM 23/08/03
25/06/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Bryan K Bowles/ORC/704-474-4191/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Benny Ray Dennis,315 N Main St Troy NC 27371//910-572-6541/9105723663
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Other
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
Sharon Moran Docusignedby: DWR/FRO WQ/910-433-3300/ 8/30/2023
LvDIn, Aurm.
EsME17E499D6943D...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Mark Brantley DWR/Division of Water Quality/910-433-3300 Ext.727/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
NCO028916 I11 12I 23/08/03 117 18 1 p I
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Enclosed, please find a copy of the Pretreatment Compliance Inspection Form from the inspection
conducted on August 3rd, 2023. The Pretreatment Compliance Inspection was conducted by Sharon
Moran, Environmental Specialist, of the Fayetteville Regional Office and Bryan Bowles, Director of
Town of Troy's POTW.
The Town of Troy WWTP is currently a 1.2 MGD permitted facility and has two (2) Significant
Industrial Users; Republic Services dba. Uwharrie Environmental, and Saputo Cheese.
Two permit files were reviewed: Republic Services dba. Uwharrie Environmental, and Saputo Cheese.
A site visit was not conducted during this inspection.
This Pretreatment Compliance Inspection report indicated that the City of Troy's Pretreatment
Program did not meet all reporting requirements as outlined in 40 CFR 122.41(I)(4), namely that not
all sampling requirements were being met in the approved Short Term Monitoring Plan. The City of
Troy has not been sampling for Oil and Grease at the approved frequency. Additionally, the slug
control and spill plan's signatures were past the integral year expiration for contact update and
re-signing. Finally, the files maintained by the WWTP did not contain the most recent enforcement
and proof of penalty collection notices.
Page#

Permit: NCO028916
Inspection Date: 08/03/2023
Other
Comment:
Owner -Facility: Troy WWTP
Inspection Type: Pretreatment Compliance
Yes No NA NE
Page#

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL QUALITY
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Troy
2. Control Authority Representative(s): Bryan Bowles
3. Title(s): Director POTW
4. Last Inspection Date: 7/20/21 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:
ICIS CODING
Main Program Permit Number
I NIC10 10 1 21 81 91 116_1
MM/DD/YY
1 08 1 03 1 23 I
Are Milestone Dates Being Met? ❑ YES ❑ NO
7. Current Number Of Significant Industrial Users SIUs ?
2
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?
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?
19. Which Industries have been in SNC for Limits or Reporting during SNC for
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pul
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?
21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
EYES ❑ NO
Feb 2022: TSS-clarifier was stuck,
so it was cleaned out
Oct 2022: BOD/weekly and
monthly Ammonia, one time slug
from industry.
® YES ❑ NO
One time slug from Saputo-NOV
Limits: None
Reporting: None
dished: None
None
❑ 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 (eDMR)
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

25.
yourself!
26.
27.
All LTMP/STMP effluent data reported on Discharge Monitoring Report? ❑ YES ® NO Division Inspector, please verify
If NO to 23 - 26, list violations Oil and grease were not sampled for
Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP?
® YES ❑ NO
If yes, which ones? Eliminated: oil and grease Added:
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)
2/12/19
® Yes ❑ No
4/24/19
® Yes ❑ No
1/31/24
Industrial Waste Survey IWS
11/21/19
® Yes ❑ No
2/12/20
® Yes ❑ No
Sewer Use Ordinance SUO
12/28/18
® Yes ❑ No
1/3/13
❑ Yes ❑ No
Enforcement Response Plan (EPP)
12/8/09
® Yes ❑ No
12/21/09
❑ Yes ❑ No
Long Term Monitoring Plan (LTMP)
11/2/20
® Yes ❑ No
12/2/20
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
Republic Services
2. Saputo Cheese
3.
db1. a. Uwharrie Environmental
30. IUP Number
0004
0003
31. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ No
❑ Yes ❑ No
32. Permit Expiration Date
1 11/30/202
1 7/31/2028
33. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
I N/A
N/A 11
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
® Yes ❑ No
❑ Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
® Yes ❑ No
® Yes ❑ No 11
❑ Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
a. ®Yes ❑No
a. ®Yes ❑No
a. []Yes ❑No
b. If No, is One Needed? See Inspection Form from POTW
b. ❑Yes ❑No
b. ❑Yes ❑No
b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Yes❑No®N/A
P
❑Yes❑NoON/A
❑Yes❑No❑N/A
Organic Management Plan TOMP ?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes ❑No
a. ®Yes ❑No
a. ❑Yes ❑No
b. All Issues Resolved?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑ No
®Yes ❑ No
❑ Yes ❑ No
its Sampling as Required b IUP, including flow?
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
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes❑No❑N/A
Sampling as Required b IUP, includingflow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑No[D
❑Yes❑No❑N/A
file includeprocess/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
❑Yes❑NoON/A
❑Yes❑No❑N/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
® Yes ❑ No
® Yes ❑ No
❑ Yes ❑ No
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes❑No❑N/A
All Re ortin Non-Com liance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑No®N/A
a.®Yes❑No❑N/A
a.❑Yes❑No❑N/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
c. If applicable, Did POTW resample within 30 days of becoming aware
c.❑Yes❑No®N/A
of SIU limit violations in the POTW's sampling of the SIU?
c.❑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
I
❑
Yes
❑
No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑No®N/A
®Yes❑No❑N/A
❑Yes❑No❑N/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

48. Does the File Contain Penalty Assessment Notices?
49. Does The File Contain Proof Of Penalty Collection?
50. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
FILE REVIEW COMMENTS:
Saputo Cheese USA file did not contain proof of penalty collection.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number
1. Industry Inspected:
2. Industry Address:
3. Type of Industry/Product:
4. Industry Contact:
Phone:
MM/DD/YY
Title:
Fax:
❑Yes❑No®N/A
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No[D
❑Yes®No❑N/A
❑Yes❑No❑N/A
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
❑ Yes ®No
❑Yes ®!o]E
Yes ❑ No
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?
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:
OVERALL SUMMARY AND COMMENTS:
Comments:
Requirements: The City of Troy must sample for Oil and Grease at the approved frequency.
Recommendations: The slug control and spill plan should have contacts updated and be re -signed. A copy of the most recent
enforcement and proof of penalty collection notices should be obtained and added to the WWTP's files.
NOD: ❑ YES ❑ NO
NOV: ® YES ❑ NO
QNCR: ❑ YES ❑ NO
POTW Rating:
Satisfactory g4inali by: X UnSatisfactory_
PCI COMPLETED BY: Lvbvu AI.Orm. DATE:
2BE17E499D6943D...
8/30/2023
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3