NC0026816_Pretreatment Inspection_20170524

Water Resources
Environmental Quality
May 24, 2017
Joe Shields
Director of POTW
Town of Troy
444 North Main Street
Troy NC 27371
SUBJECT: Pretreatment Compliance Inspection (PCI) Report
Troy WWTP
NPDES Permit No: NC0028916
Montgomery County,
Dear Mr. Shields:
ROY COOPER
Governor
MICHAEL S. REGAN
,Secretary
S. JAY ZIMMERIVIAN
Director
Enclosed please find a copy of the Pretreatment Compliance Inspection report from the inspection
conducted on 05/23/2017, at the Town of Troy Wastewater Treatment Plant, in which I met with Joe
Shields (Pretreatment Coordinator). The Inspection was conducted by Johnathan Watts, Environmental
Specialist, of the Fayetteville Regional Office. The report indicates that the Troy POTW met the
pretreatment requirements as outlined in 15A NCAC 2H .0900 for Local Pretreatment Programs.
Please refer to the enclosed inspection report for additional observations and comments. If you or your
staff have any questions, please call me at 910-433-3322.
Sincerely,
Johnathan C. atts
Environmental Specialist
Division of Water Resources
Water Quality Regional Operations Section
cc: PERCS Unit
I FRO Pretreatment Files (J1N)
Corpares7-+,
State of North Carolina I Environmental Quality
225 Green Street, Suite 714, Fayetteville, North Carolina 28301-5095
910-433-3300

United States Environmental Protection Agency
E P Q Washington, D.C. 20460
Water Compliance Inspection Report •Approval
Form Approved.
OMB No. 2040-0057
expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection
1 H 2 IL I 3. 1 NC0028916 111 12 1 17/05/23 117
Type
18 I D I
I I I I I
Inspector Fac Type
19 I G I 20I
211 1 1 1 1 1 1 1 1 1 1 1 1 i i I I I I 1 I I I' I I I I I
I I I
I I I I I r6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA
67 I 1 70 I 1 71 f I•72 1 N I
Reserved----
—
731 _ I.174 751
I I I I I I 180
Section B: FacilityDataData
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Troy WWTP .
650 Glen Rd
Troy NC 27371 ,
Entry Time/Date
10:OOAM 17/05/23
Permit Effective Date
15/08/01
Exit Time/Date
12:OOPM _ 17/05/23
Permit Expiration Date
19/06/30 •
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Joseph Edward Shields/ORC/910-572-3661/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Benny Ray Dennis,315 N Main St Troy NC 27371//910-572-7841/9105723663
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
Johnathan C Watts FRO WQ//910-433-3300/ �.RG 5 -aA- if i
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Trent Alle�i ��FRO WQ//910-433-3300/ S-73 067
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1

3I
NPDES
NC0028916
111 121
yr/mo/day
17/05/23
Inspection �Type
17 18
(Cont.)
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
The report indicates that the Troy POTW met the pretreatment requirements as outlined in 15A NCAC
2H .0900 for Local Pretreatment Programs.
Although the IUPs do not require Slug Control Plan, the Pretreatment file contained one for each SIU.
Town of Troy issued NOVs to Wright Foods for exceeding daily maximum of 1200 mg/L for BOD. In
accordance with the ERP, the Town of Troy issued a civil penaly of $100. Town of Troy issued NOVs
in March of 2017 in response to pH violations from January and February of 2017.
IUP was issued to Republic Services of NC, Uwharrie Environmental, on 12/01/2016. The landfill
averaged 61,000 GPD for April 2017.
Thank you for your continued cooperation with the Pretreatment Program. Please do not hesitate to
contact me at 910-433-3322 or Deborah Gore at 919-807-6383 [[e-mail]] or Monti
Hassan at 919-807-6314 [[e-mail]] if you have any questions or concerns.
Page# 2

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
NViRCt:MENT'A: QU'A.-Y
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority (POTW) Name: Town of Troy
2. Control. Authority Representative(s): Joe Shields
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 06/21/2016 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 Z NO
Order Type, Number, Parameters: Are Milestone Dates Being Met? ❑ YES ® NO
ICIS CODING
Main Program Permit Number
MM/DD/YY
f N I C! 0 1 0 1 2 1 81 91 1 1 6 1 1 05 1 23 I 17 I
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 S1Us on Schedules?
0
15. Current Number Of Categorical Industrial Users (ClUs)?
0
16. Number of ClUs 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
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
SNC for
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?
❑ YES /ZI NO
❑ YES ►d NO
Limits:0
Reporting:0
lished:0
N/A
❑ YES /1 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? ►1 YES ❑ NO Division 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:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element to ,
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)
02/02/2014
/1 Yes ❑ No
04/11/2014
/i1 Yes ❑ No
01/31/2019
Industrial Waste Survey (1WS)
01/06/2015
►I Yes ❑ No
02/06/2015
/i1 Yes ❑ No
12/31/2019
Sewer Use Ordinance (SUO)
12/28/2012
1 Yes ❑ No
01/03/2013
r Yes ❑ No
Enforcement Response Plan (ERP)
12/08/2009
/i1 Yes ❑ No
12/21/2009
IZI Yes ❑ No
Long Term Monitoring Plan (LTMP)
12/08/2009
i1 Yes ❑ No
12/21/2009
/I Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 lU INSPECTION)
29. User Name
1. Wright Foods 2. Uwharrie
3.
30. IUP Number
0003
0004
31. Does File Contain Current Permit?
►1 Yes ❑ No
' Yes ❑ No
❑ Yes ❑ No
32. Permit Expiration Date
08/01/2018
11/30/2021
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
N/A
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
i1 Yes ❑ No
0 Yes ❑ No
❑ Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
Yes ❑ No
/i1 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. _EYes IN No
b. ■Yes ■ No
a. _EYes ■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. JYes ■No
b.❑Yes ❑No®N/A
a. _EYes ■No
b.❑lies❑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
►ZI Yes ❑ No
❑ Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
'1 Yes ❑ No
/1 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❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑No❑N/A
42b. For categorical lUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑NoEN/A
❑Yes❑NoEN/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
/1 Yes ❑ No
❑ Yes ❑ No
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑ Yes ❑NoEN/A
❑ Yes ❑NoEN/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 ❑NOON/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.)?
LEI Yes ❑No❑N/A
❑ Yes ❑NoEN/A
❑Yes❑No❑N/A
48. Does the File Contain Penalty Assessment Notices?
EYes❑No❑N/A
❑Yes❑NoEN/A
❑Yes❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection?
EYes ❑No❑N/A
❑Yes❑NoEN/A
❑Yes❑No❑N/A
50. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes ❑NoEN/A
b.❑Yes ❑No®N/A
a.❑Yes ❑No®N/A
b.❑Yes ❑No0N/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 iI No
❑ Yes ❑ No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

FILE REVIEW COMMENTS:
Republic Services of NC, Uwharrie Environmental's IUP was issued 12/01/2016.
POTW performs all sampling
All files were available for direct access. Excellent records management.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number
MM/DD/YY
1. Industry Inspected:
2. Industry Address:
3. Type of Industry/Product:
4. Industry Contact: Title:
Phone: Fax:
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:
During the pretreatment inspection, a formal inspection and evaluation on how the program performs an industrial user inspection was not
performed.
OVERALL SUMMARY AND COMMENTS:
Comments:
Requirements:
Recommendations:
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory X Marginal UnSatisfactory
PCI COMPLETED BY: Johnathan C. Watts DATE: 05/23/2017
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

IUP, Part 1 Section F:
Effluent Limits and Monitoring Requirements
The Permittee may discharge from this specific
Pipe number according to these specific dates,
effluent limits, and monitoring requirements
Receiving POTW name =>
Receiving POTW NPDES # =>
Effective date for these Limits =>
Expiration date for these Limits =>
Troy POTW IU name =>•..
NC0028916 IUP # _>
December 1, 2016 Pipe # _>
November 30, 2021 40 CFR # _>
THE LIMITS ON THIS PAGE ARE, (Check one below):
LIMITS for ENTIRE permit period =>
INTERIM Limits for period # 1 =>
INTERIM Limits for period # 2 =>
FINAL Limits Page =>
XX
Uwharrie Environmental
0004
01
NA
if not applicable put N/A
Concentration Limits
Mass Limits
Monitoring Frequency
Daily Max
Monthly
Average
Units
Daily Max
Monthly
Average
Units
By Industry
By POTW
Sample
Collection
Method
(C or G)
Required
Laboratory
Detection
Level
1
Flow
.010 *
MGD
Daily
Every sample
Staff gauge
2
BOD
2400
mg/L
Monthly
G
2.0 mg/L
3
TSS
300
mg/L
Monthly
G
2.5 mg/L
4
NH3
125
Lbs
Weekly
G
0.1 mg/L
5
PH
5-10
SU
Monthly
G
PH
OTHER PARAMETERS; Please List Alphabetically
6
Arsenic
ug/L
Monthly
G
2.0 ug/L
7
Cadmium
ug/L
Monthly
G
2.0 ug/L
8
Chromium
ug/L
Monthly
G
5.0 ug/L
9
Copper
ug/L
Monthly
G
2.0 ug/L
10
Lead
ug/L
Monthly
G
10 ug/L
11
Mercury
ug/L
Monthly
G
.2 ug/L
12
Molybdenum
ug/L
Monthly
G
5.0 ug/L
13
Nickel
ug/L
Monthly
G
10 ug/L
14
Phosphorus
ug/L
Monthly
G
20 ug/L
15
Silver
ug/L
Monthly
G
5.0 ug/L
16
Zinc
ug/L
Monthly
G
50 ug/L
17
•
18
.
19
20
21
22.
23
4

•
TOWN OF TROY
Control Authority and/or Municipality
PERMIT
Industrial User Pretreatment Permit (IUP)
To Discharge Wastewater Under the
Industrial Pretreatment Program
0004 NA
IUP Number 40 CFR Category(if Applicable)
In compliance with the provisions of North Carolina General Statute 143-215.1, any
applicable federal categorical pretreatment regulations, all other lawful standards and
regulations promulgated and adopted by .the North Carolina Environmental Management
Commission, and the Control Authority and/or Municipality Sewer Use Ordinance. The
following Industry, hereafter referred to by name or as the permittee:
Industry name, pernittee:
Republic Services of NC, LLC dba Uwharrie Environmental
Facility Located at Street Address
500 Landfill Rd.
City
Mt. Gilead
State, Zp
NC 27306
r
is hereby authorized to discharge wastewater from the facility located at the above listed
address into the sanitary sewer collection system and the wastewater treatment facility of
the Control Authority and/or Municipality listed below:
IUP Control Authority and/or Municipality W WTP name:
Town of Troy
NPDES Number.
NC0028916 •
W WTP Address
315 N Main St.
City, State, Zip
Troy,
in accordance with effluent limitations, monitoring requirements, and all other conditions
set forth in Parts I, II, and III of this Industrial User Pretreatment Permit (IUP).
Effective date, this permit and the authorization to discharge shall become
effective at midnight on this date:.
12/01/2016
Expiration date, this permit and the authorization to discharge shall expire at
midnight on this date:
11/30/2021
Date signed

Industrial User Pretreatment Permit (IUP)
PART I
Specific Conditions
G.) Definitions and Limit Page(s) notes:
In addition to the definitions in the Town of Troy Sewer Use Ordinance the
following definitions and requirements apply:
1 Composite Sample:
NA
2. Composite Sample, alternative defmition:
NA
3. Daily Monitoring Frequency
Daily Monitoring Frequency as specified in this IUP shall mean each day
of discharge.
4. Grab Sample
Grab sample for the monitoring requirements of this IUP, is defined as a
single "dip and take" sample collected at a representative point in the
discharge stream.
5. Instantaneous measurement
An Instantaneous measurement for the monitoring requirements of this
IUP is defined as a single reading, observation, or measurement.
5

TOWN OF TROY
August 18, 2016
Mr. Tyler Brown
Wright Foods
1 Wright Way
Troy, NC 27371
RE: Notice of Violation
July 2016
Wright Foods
Permit #0003
Mr. Tyler Brown
Wright Foods has been found to be in violation of Part 1 Section F of
Wastewater Discharge Permit (#0003) issued by the Town of Troy. The
violations are summarized as follows.
ROY MA1lESS
MAYOR
JAMES HURLEY
MAYOR PRO-TEM
COMMISSIONERS:
ANGELA ELKINS
BRUCE HAMILTON
WALLACE JONES
DAMON PRINCE
GREG ZEPHIR
TOWN MANAGER
CATHY M. MANESS
TOWN CLERK
In July 2016 the daily maximum of 1200 mg/L for BOD was exceeded: July
27/28 the daily maximum for BOD was >1473 mg/L.
In accordance with the Town's Enforcement Response Plan, The Town's
Pretreatment Section / Wastewater Division assesses Wright Foods a
$100.00 civil penalty. Payment of the civil penalty and a report outlining the
steps Wright Foods will undertake to become compliant must be submitted
to this office within 30 days.
If Wright Foods fails to meet the permit limits, then additional actions,
including increased penalties or issuance of an enforceable order, will be
completed in accordance with the Town's Enforcement Plan. The Town's
Sewer Use Ordinance gives the Director the authority to assess penalties of
up to $25,000 per day per violation.
315 NORTH MAIN STREET TROY, NC 27371
PHONE: [phone] FAX: [phone]
www.troy.nc.us

The appeal of civil penalties is provided for in section 4.2(h) of the Town's Sewer Use
Ordinance. If you wish to appeal the penalty assessment, written demand identifying the
specific issues to be contested must be made to the Director within 30 days of the receipt of this
letter. Contact the Director if you have any questions.
Joseph Shields
A,4:0eflp
rector POTW
Public Works Dept / Wastewater Division
315 North Main Street, Troy, North Carolina 27371
phone: [phone] facsimile: [phone] [e-mail]

TOWN OF TROY
ROY MANESS
MAYOR
JAMES HURLEY
MAYOR PRO-TEM
COMMISSIONERS:
ANGELA ELKINS
BRUCE HAMILTON
WALLACE JONES
DAMON PRINCE
• GREG ZEPHIR
TOWN MANAGER
CATHY M. MANESS
TOWN CLERK
March 8, 2017
Mr. Tyler Brown
Wright Foods
1 Wright Way
Troy, NC 27371
RE: Notice of Violation
January / February 2017
Wright Foods
Permit #0003
Mr. Tyler Brown
Wright Foods has been found to be in violation of Part 1 Section F of
Wastewater Discharge Permit (#0003) issued by the Town of Troy. The
violations are summarized as follows.
January and February 2017 there were numerous reported PH values (17)
below the permitted limit of 6 SU. The permit requires that the PH be
maintained between 6-9 SU.
If Wright Foods continues to fails to meet the permit limits, then additional
actions, including increased penalties or issuance of an enforceable order,
will be completed in accordance with the Town's Enforcement Plan. The
Town's Sewer Use Ordinance gives the Director the authority to assess
penalties of up to $25,000 per day per violation.
315 NORTH MAIN STREET TROY, NC 27371
PHONE: [phone] FAX: [phone]
www.t roy.nc.nS

Within 30 days from the date on this notice, an explanation for the violation
and a plan for the satisfactory correction thereof shall be submitted to this
office.
d,..,...,-2„..,a,
oseph Shields
Director POTW
315 N Main St.
Troy, NC 27371

March 22, 2017
• Mr. Joseph Shields
Director POTW
315 N. Main Street
Troy N.C. 27371
Re: Notice of Violation
Dear Mr. Shields:
This letter is in response to the notice of PH discharges found in violation
during the testing from the period of time noted January and February 2017.
We found the operator of the system (David Hayes) did not completely
understand the range on the lower limit and discharged wastewater with
incorrect PH levels. He has been retrained and understands the PH range is
to be maintained for discharge between the ranges of 6-9.
We do not expect that this will occur again and was isolated to that period of
time.
If there are any further questions please do not hesitate to reach out to us.
/6v1--
Respectfully,
Bob Rogers
General Manager