NC0028916_NOV-2021-PC-0290_20210518

ROY COOPER
Governor
DIONNE DELL[ -GATT[
Secretary
5. DANIEL SMITH
Director
Certified Mail # 7020 0090 0001 7206 8699
Return Receipt Requested
NORTH CAROLINA
Environmental Quality
May 18, 2021
Greg Zephir, Town Manager
Town of Troy
315 N Main St
Troy, NC 27371
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2021-PC-0290
Permit No. NC0028916
Troy WWTP
Montgomery County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Troy WWTP on April 19, 2021.
This inspection was conducted to verify that the facility is operating in compliance with the conditions and
limitations specified in NPDES WW Permit No. NC0028916. 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 Fayetteville
Regional Office. The following violation(s) were noted during the inspection:
Inspection Area Description of Violation
Equalization Basins- Improper operation and maintenance. The EQ basin was breached during Hurricane Florence
in 2018. A temporary repair wall was constructed to stabilize the basin and prevent the loss of anymore
wastewater. However, a permanent repair to the berm wall, designed by a NC Processional Engineer, has still not
yet been constructed.
Furthermore, the Town of Troy's NPDES Permit NC0028916 states:
Section C. Operation and Maintenance of Pollution Controls
2. Proper Operation and Maintenance
The Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control
(and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions
of this permit. Proper operation and maintenance also includes adequate laboratory controls, and appropriate
quality assurance procedures. This provision requires the Permittee to install and operate backup or auxiliary
D_Q
North Carolina Deportment of Environmental Quality I Division of Water Resources
Fayetteville Regional ice 1225 Green Street Sure 714 I Fayetteville. North Carolina 28301
910.4333300

facilities only when necessary to achieve compliance with the conditions of the permit {40 CFR 122.41 (e)}.
The Town of Troy's WWTP equalization basin was damaged during Hurricane Florence which resulted in the loss of
17 million gallons of wastewater to Spencer Branch. After the storm, temporary repairs were made to the wall of
the basin. Since the time of the temporary repairs, four Notices of Violations have been issued for by-passes of
wastewater occurring at the temporary repair site or from the manhole in front of the equalization basin because
additional wastewater could not be added to the basin.
NOV's issued
• NOV-2019-PC-0710
• NOV-2020-PC-0035
• NOV-2020-PC-0058
• NOV-2020-PC-0059
Civil penalties were not assessed because the Town of Troy indicated that a more permanent repair was being
planned. Another bypass occurred on February 19, 2021, when wastewater was pumped from the equalization
basin to the old contact chamber to prevent an overflow at the basin that could have damaged the temporary
repair. This wastewater was partially treated with chlorine and de -chlorinated before it was discharged to the
receiving stream. This bypass will be issued a Notice of Violation with Intent to Assess a Civil Penalty in a separate
letter.
To prevent further action regarding this Notice of Violation, 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 violation regarding a permanent repair to the equalization basin wall.
If you should have any questions, please do not hesitate to contact Hughie White or myself with the Water Quality
Regional Operations Section in the Fayetteville Regional Office at 910-433-3300.
Sincerely,
DocuSigned by:
I
E4E1A9691DB248E_.
Mark Brantley, Asst. Regional Supervisor
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: WQS Fayetteville Regional Office (HW)
D_E
North Carolina Department of Environmental Quality I Division of Water Resources
Fayetteville Regional Office 1225 Green Street, Suite 1]4 I Fayetteville. North Carolina 28301
910.4333300