NC0062855_NOV-2019-TX-0043_20191004

ROY COOPER
Governor
MICHAEL S. REGAN
se nary
LINDA CULPEPPER NORTH CAROLINA
Director Environmental Quality
October 4, 2019
CERTIFIED MAIL: 7019 0140 0001 1259 0561
Mr. David Lambert
Town of Robbins
PO Box 296
Robbins, NC 27325
SUBJECT: NOTICE OF VIOLATION: NC NOV-2019-TX-0043
Whole Effluent Toxicity (WET) Testing
NPDES Permit No. NC0062855/001
Robbins WWTP
Moore County
Dear Mr. Lambert:
DECUDWR
OCT 09 2019
`LiREIckI j'.U€COERCE
This is to inform you that the Aquatic Toxicity Branch, ATB, has not received your toxicity self -monitoring report form for
the month of July 2019. This is in violation of Title 15A of the North Carolina Administrative Code, Chapter 2, Subchapter
2B, Section .0506 (a)(1)(A) which states that "monthly monitoring reports shall be filed no later than 30 days after the end
of the reporting period for which the report was made."
Information contained on your eDMR and gathered through correspondence with the Fayetteville Regional Office
indicates that a toxicity test was not conducted during the month July 2019.
Please remember that reporting of toxicity self -monitoring data is a dual requirement. Toxicity test results must be
entered on your Discharge Monitoring Report and the Toxicity Reporting Form (AT Report Form) must be submitted to:
North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
or emailed to [e-mail] within the required time frame. This information and the following statement can
be found in section A. (3.) of your permit: "Should the permittee fail to monitor during a month in which toxicity monitoring
is required, then monthly monitoring will begin immediately until such time that a single test is passed."
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity Monitoring and
Reporting Requirements. We encourage you to review this information; if it would be helpful to discuss this situation or
possible solutions to resolve effluent toxicity noncompliance, please contact Ms. Cindy Moore at [phone] or
Ms. Hannah Headrick at (919) 743- 8439'
cc: FT e — f
Central Files
Cindy Moor, Suer`visor Acjuatic Toxicology Branch
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality I Division of Water Resources / Water Sciences Section
4401 Reedy Creek Road 11621 Mail Service Center I Raleigh, North Carolina 27699-1621
919-743-8400

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity testing and reporting
information. Please take time to review this information. The items below do not address or include all the toxicity testing and
reporting requirements contained in your NPDES permit. If you should have any questions about your toxicity testing requirement,
please contact Ms. Susan Meadows with the Aquatic Toxicology Branch at [phone] or Ms. Cindy Moore at [phone].
> The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that toxicity report
forms are appropriately filed.
> The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered (with the appropriate
parameter code) on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Resources
Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
IN ADDITION
Toxicity test data ("AT" form) must be submitted to the following address:
North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicity Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
or
Email to: [e-mail]
➢ Toxicity test results shall be filed with the Water Sciences Section no later than 30 days after the end of the reporting period (eg,
January test result is due by the end of February).
> Toxicity test condition‘language contained in your NPDES permit may require use of multiple concentration toxicity testing upon failure of
any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the permit limit, then at least two
multiple concentration toxicity tests (one per month) will be conducted over the following two months. As many analyses as can be
completed will be accepted. If your NPDES permit does not require use of multiple concentration toxicity testing upon failure of any
single quarterly test, you may choose to conduct either single concentration toxicity testing or multiple concentration toxicity testing per
the Division's WET enforcement initiatives effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the
Division's enforcement response.
> Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity monitoring
requirements (eg, if the testing months specified in your NPDES permit are March, June, September, and December, then toxicity testing
must be conducted during these months).
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30, then you must
provide written notification to the Water Sciences Section by June 30 that a discharge did not occur during the first six months of the
calendar year.
➢ If you receive notification from your contract laboratory that a test was invalidated, you should immediately notify the Water Sciences
Section at [phone] and provide written documentation indicating why the test was invalidated and the date when follow-up
testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should complete the information
block located at the top of the AT form indicating the facility name, permit number, pipe number, county and the month/year of the
subject report. You should also write "No Flow" on the AT form, sign the form and submit following normal procedures.
> The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge (ORC) except for facilities which have not
received a facility classification. In these cases, a duly authorized facility representative must sign the AT form. The AT form must also be
signed by the performing lab supervisor.
> To determine if your AT test forms were received on time by the Division of Water Resources, you may c'bnsider submitting your toxicity
test results certified mail, return receipt requested to the Water Sciences Section or email to the above address, receiving e-confirmation.