NC0028916_NOV-2019-PC-0680_20191008

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Article Addressed to:
BENNY RAY DENNIS
TOWN OF TROY
315 N MAIN ST
TROY, NC 27371
11111111111111111111111111111111111111111111111
9590 9402 5233 9122 2938 25
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Permit No. G-10
NCDEQ — FA.YETTEVILLE REGIONAL OFFICE
DIVISION OF WATER RESOURCES
ATTN: MARK B fft
225 GREEN STR� �E41
FAYETTEVILLE NC 28301
OCT 15 2019
Id:
PiI11111101,13; ji 11 iiii 11il 1'i 1111i 1111111 11 ji J IH.11"liiiilii

MAYOR
SHERRI HARRIS ALLGOOD
MAYOR PRO-TEM
BRUCE HAMILTON
COMMISSIONERS
KAYREN BRANTLEY
ANGELA ELKINS
WALLACE JONES
DAMON PRINCE
O
NORTH MAI
CAROLINA
TOWN MANAGER
GREG ZEPHIR
TOWN CLERK
CATHY MANESS
ATTORNEY
RUSSELL J. HOLLERS, III
a—Y9 A'L6Yf9_S
Mark Brantley 01ED
NCDEQ FRO ! Yi18
225 Green Street, Suite 714
Fayetteville, NC 23001-5905 NOV 13 2019
RE: Notice of Violation, NOV-2019-PD-0680
Compliance Inspection Report
Troy WWTP
NPDES WW Permit No. NCO028916
Montgomery County
Dear Mr. Brantley:
WOPOS
FA'IETTE-in, i OFFIC,=
We appreciate this opportunity to provide clarifidation as to why the damage inflicted on the Town wastewater
treatment plant (WWTP) equalization (EQ) basin by Hurricane Florence on September 181, 2018, has not been fully
resolved and a status update on the Town's interim and permanent repair efforts.
On or about September 26, 2018, the Town placed a row of sandbags across the invert area of the breach as an interim
breach closure/abatement measure. Those sandbags have remained in place since that time.
A permanent repair of the damage has been a matter of continual effort on the part of the Town in conjunction with
FEMA and NC DPS Emergency Management from the time a claim for the damage was submitted to FEMA after
Montgomery County was included as part of the Hurricane Florence National Disaster declaration area. The Town is
currently awaiting a response from FEMA on a revised damage repair design concept and opinion of cost which was
submitted to FEMA by the Town last month. The Town has already submitted a request to FEMA so that once a
damage repair design approach and estimate is mutually agreed upon by FEMA and the Town, those funds can be
allocated to the Town for use on an Alternate Project under Section 428. Under the Section 428 program, the Town
will then submit a plan to FEMA for restoration of the EQ basin as a mitigation project.
The actual project being planned for implementation, which will be presented to your office for approval once the
funding arrangements are fmalized with FEMA, will consist of the construction of a berm -enclosed area located in
the northwest area of the existing EQ basin. The berm will impound approximately 2.3 acres of area and provide an
initial EQ basin volume of approxir-iately 1 million gallons. The remaining portion of the existing EQ basin,
comprising approximately 11 acres, will be abandoned in accordance with NCDWR guidelines. The estimated cost
for construction of the replacement, reduced -size EQ basin is approximately $0.5 million.
The anticipated timeline for completion will be totally dependent on access to FEMA funds and the FEMA process,
but the current expectation is that funding arrangements should be completed by end of the year. Design and
permitting is anticipated to require 3 months and construction possibly 4 to 5 months. We will do everything in our
power to compress this timeline as much as is possible while remaining in compliance with FEMA requirements.
Please let us know if you have any questions.
Sincerely,
Greg Zephir
Town Manager
TROY. NC.US 1 315 N MAIN STREET I TROY, NC 27371 1 910-572-3661
THE TOWN OF TROY IS AN EQUAL OPPORTUNITY PROVIDER AND EMPLOYER.

Governor
Ray coopat
MICHAEL S. REGAN-
secre!wy
LINDA CULPEPPE-k
Director
NORTRCAROLINA
Enytronmentaf QuaW
Certified Mail # 7015 0640 0007 8168 9091
Return Receipt Requested
October 08, 2019
Benny Ray Dennis
Town of Troy
315NMain St
Troy, NC 27371
SUBJECT: NOTICE OF VIOLATION, NOV-2019-PC-0680
Compliance Inspection Report
Troy WWTP
NPDES WW Permit No. NCO028916
Montgomery County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Troy.WWTP on
9/17/2019. .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. The findings and comments
noted during this inspection are provided in the enclosed copy of the inspection report entitled
"Compliance Inspection Report". -
Please respond in writing to this office within 30 daysof your receipt of this letter regarding your plans
or measures to be taken to address the following:
VIOLATION
Section C. Operation and Maintenance of Pollution Controls
2. Proper Oberation.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.
North Cafoks Department & Emvronrhenta) Yua#aty I Di+ds'.on of Wstsr Res-:)u3aes'
Fayettemife R gonai' Ofm 1 225 Green Str= t, Suke 714 1 Fay ttav di=, North Carogna 2sr". U

On September 17, 2018 the dam on the equalization basin was breached due to heavy rains and flooding from
Hurricane Florence. Since then, the Town of Troy has been in contact with their engineering firm on how to
repair this structure. However, during periods of high flows, wastewater is still allowed to enter the
equalization basin. This wastewater has the potential to discharge through the breach into Spencer Creek,
which runs behind the equalization basin. This discharge of wastewater would be considered a by-pass of the
wastewater treatment system. The Town of Troy could then be assessed a civil .penalty for an unpermitted
and illegal discharge of wastewater to Waters of the State.
The Fayetteville Regional Office suggests that the town permanently or temporarily fix the breach in the
equalization basin to prevent an unpermitted discharge of wastewater that entered the basin from the
collection system or stormwater mixing with residuals (then stormwater becomes wastewater). If the town
valves off the line leading to the equalization basin then, during high flows, wastewater will then exit the
collection system at the lowest spot and that bypass/SSO would need to be reported to the regional office, as
required, by the facility's NPDES permit or the Town's Collection System permit.
Please have a structural evaluation performed on the Equalization Basin by a North Carolina Licensed
Professional Engineer to ensure the integrity of this treatment unit.
Comments
*Need to move the bisulfite drip to a location upstream of the effluent sampling location: As a reminder
the effluent sample should be taken after all treatment.
*The June 2019 eDMR was compared to laboratory bench sheet. Please correct the data in the
temperature column and on June 26, 2019 the BOD result was reported as >2 mg/I but the laboratory
sheet reported*the BOD as <2 mg/I. Please the correct the errors on the eDMR and submit a revised
copy.
If you should have any questions, please do not hesitate to contact Mark Brantley with the Water
Quality Regional Operations Section in the Fayetteville Regional Office at 910-433-3300 or via email at
[e-mail].
Sincerely,
OocuSigned by;
E4 E1A9691 DB248E...
Mark Brantley, Assistant Regional Supervisor
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: 1. 5 aayette if tionafgOffice marlaBraotl2ft
North Csrohms.Department ofEnvuorme ta'Qua:ty. I DvisbnofWaterFteswrces
FayetteoAfe RagonalOf -e 1 225 Green Street, Srate.714 I Fs attevUs. North Carolina 28301
' ` s 910-433-3-200

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
1
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 15 1 3 I NCO028916 111 121 19/09/17 117 18 1_ 1 19 I G I 201 I
Lij
2111 1 1 1 1 1 1 1 1 11 11 1 1 I 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 11 1 I 1 1 1 166
I
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA -Reserved
67 70 71 L_j 72 L1 N J 73 I I 174 751 1 1 1 1 1 I 180
J I I I
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)
10:30AM 19109/17
15/08/01
Troy WWrP
Exit Time/Date
Permit Expiration Date
650 Glen Rd
01:15PM 19/09/17
19/06/30
Troy NC 27371
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Numbers)
Other Facility Data
Bryan K Bowles/ORC/704-474-4191/
Name, Address of Responsible Ofricialrritle/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)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review. Effluent/Receiving Waters
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 Fait Numbers Date
Mark Brantley DWR/FRO WQ/910-433-3300 Ext.727/
Signature wa R A Reviewer Agency/Office/Phone and Fax Numbers Date
k" tmv&,, 10/9/2019
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type (Corp.)
31 NCO028916 I11 12 19/09/17 17 18 ISI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
VIOLATION
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.
On September 17, 2018 the dam on the equalization basin was breached due to heavy rains and
flooding from Hurricane Florence. Since then, the Town of Troy has been in contact with their
engineering firm on how to repair this structure. However, during periods of high flows, wastewater is
still allowed to enter the equalization basin. This wastewater has the potential to discharge through the
breach into Spencer Creek, which runs behind the equalization basin. This discharge of wastewater
would be considered a by-pass of the wastewater treatment system. The Town of Troy could then be
assessed a civil penalty for an unpermitted and illegal discharge of wastewater to Waters of the State.
The Fayetteville Regional Office suggests that the town permanently or temporarily fix the breach in the
equalization basin to prevent an unpermitted discharge of wastewater that entered the basin from the
collection system or stormwater mixing with residuals (then stormwater becomes wastewater). If the
town valves off the line leading to the equalization basin then, during high flows, wastewater will then
exit the collection system at the lowest spot and that bypass/SSO would need to be reported to the
regional office, as required, by the facility's NPDES permit or,the Town's Collection System permit.
Please have a structural evaluation performed on the Equalization Basin by a North Carolina Licensed
Professional Engineer to ensure the integrity of this treatment unit.
Need to move the bisulfite drip to a location upstream of the effluent sampling location. As a reminder
the effluent sample should be taken after all treatment.
The June 2019 eDMR was compared to laboratory bench sheet. Please correct the data in the
temperature column and on June 26, 2019 the BOD result was reported as >2 mg/I but the laboratory
sheet reported the BOD as <2 mg/I. Please the correct the errors on the eDMR and submit a revised
copy.
Page#

Permit: NCO028916
Inspection Date: 09/17/2019
Owner - Facility: Troy WWTP
Inspection Type: Compliance Sampling
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable .0 ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: process controls used - TSS color, UV transmittance settleable solids, PH, dissolved
oxygen
Permit
Yes No NA NE
(if the present permit expires in 6 months or less). Has the'permittee submitted a new
M
❑
❑
❑
application?
Is the facility as described in the permit?
❑
❑
❑
# Are there any special conditions for the permit?
❑
❑
0
❑
Is access to the plant site restricted to the general public?
E
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment:
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
❑
❑
Q
Are all records maintained for 3 years (lab. reg. required 5 years)?
0
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
E
❑
❑
❑
Is the chain -of -custody complete?
❑
❑
❑
Dates, times and location of sampling
.
Name of individual performing the.sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: -do they include all permit parameters?
❑
❑
0
Has the facility submitted its annual compliance report to users and DWQ?
N
❑
❑
❑
(If the*facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
❑
❑
M
❑
on each shift?
Is the ORC visitation log available and current?
❑
❑
❑
Is the ORC certified at grade equal to or higher•than the facility classification?
E
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
❑
❑
❑
Is a copy of the current NPDES permit available on site?
❑
❑
❑
Page#
3

Permit NC0028916 Owner - Facility: Troy WWTP
Inspection Date: 09/17/2019 Inspection Type: Compliance Sampling
Record Keeping Yes No NA NE
Facility has copy of previous year's Annual Report on file for review? M ❑ ❑ ❑
Comment:
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? 0 ❑ ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ ❑
If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ M ❑
Comment:
Flow Measurement - Influent
Yes No NA NE
# Is flow meter used for reporting?
0
❑
❑
❑
Is flow meter calibrated annually?
N
❑
❑
❑
Is the flow meter, operational?
-M
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
0
❑
Comment:
Aerobic Digester
Yes No NA NE
Is the capacity adequate?
0
❑
❑
❑
Is the mixing adequate?
N
❑
❑
❑
Is the site free of excessive foaming in the tank?
M
❑
❑
❑
# Is the odor acceptable?
M
❑
❑
❑
# Is tankage available for properly waste sludge?
0
❑
❑
❑
Comment:
Solids Handling Equipment
Yes No NA NE
Is the equipment operational?
0
❑
❑
❑
Is the chemical feed equipment operational?
0
❑
❑
❑
Is storage adequate?
M
❑
❑
❑
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
❑
❑
M
❑
Is the site free of sludge buildup on belts and/or rollers of filter press?
❑
❑
M
❑
Is the site free of excessive moisture in belt filter press sludge cake?
❑
❑
M
❑
The facility has an approved sludge management plan?
M
❑
❑
❑
Comment: Sludge is disposed of at the landfill.
Page# 4

Permit: NC0028916
Owner - Facility: Troy WWTP
Inspection Date: 09/17/2019
Inspection Type: Compliance Sampling
Solids'Handling Equipment
Yes No NA NE
Pump Station - Influent
Yes No NA NE
Is the pump wet well free of bypass lines or structures?
�.
❑
❑
❑
Is the wet well free of excessive grease?
0
❑
❑
❑
Are all pumps present?
N
❑
❑
❑
Are all pumps operable?
M
❑
0
❑
Are float controls operable?
0
❑
❑
❑
Is SCADA telemetry available and operational?
❑
❑
❑
Is audible and visual alarm available and operational?
❑
❑
0
M
Comment:
Bar Screens
Yes No NA NE .
Type of bar screen
a.Manual
❑
b.Mechanical
Are the bars adequately screening debris?
0
❑
. ❑
❑
Is the screen free of excessive debris?
0
0
❑
❑
Is disposal of screening in compliance?
N
❑
❑
❑
Is the unitin good condition?
❑
❑
❑
0
Comment:
Grit Removal
Yes No NA NE
Type of grit removal
a.Manual
❑
b.Mechanical
0
Is the grit free of excessive organic matter?
M ❑ ❑ ❑
Is the grit free of excessive odor?
0 ❑ ❑ ❑
# Is disposal of grit in compliance?
M' ❑ ❑ ❑
Comment:
Secondary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
0
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
N
❑
' ❑
❑
Page# 5

Permit: NCO028916 Owner - Facility: Troy WWTP
Inspection Date: 09/17/2019 Inspection Type: Compliance Sampling
Secondary Clarifier
Yes No NA NE
Are weirs level?
0
❑
❑
❑
Is the site free of weir blockage?
0
❑
❑
❑
Is the site free of evidence of short-circuiting?
N
❑
❑
❑
Is scum removal adequate?
0
❑
❑
❑
Is the site free of excessive floating sludge?
0
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the return rate acceptable (low turbulence)?
0
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
0
❑
❑
. ❑
Is the sludge blanket level acceptable? (Approximately '/< of the sidewall depth)
0
❑
❑
❑
Comment:
Oxidation Ditches
Yes No NA NE
Are the aerators operational?
❑
❑
❑
Are the aerators free of excessive solids build up?
❑
❑
❑
# Is the foam the proper color for the treatment process?
M
❑
❑
❑
Does the foam cover less than 25% of the basin's surface?
0
❑
❑
❑
Is the DO level acceptable?
M
❑
❑
❑
Are settleometer results acceptable (> 30 minutes)?
❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
0
❑
❑
❑
Are settelometer results acceptable?(400 to 806 ml/I in 30 minutes)
❑
❑
❑
Comment:
Disinfection - UV
Yes No NA NE
Are extra UV bulbs available on site?
N
❑
❑
❑
Are UV bulbs clean?
0
❑
❑
❑
Is UV intensity adequate?
N
❑
❑
❑
Is transmittance at or above designed level?
0
❑
❑
❑
Is there a backup system on site?
0
❑
❑
❑
Is effluent clear and free of solids?
N
❑
❑
❑
Comment:
De -chlorination Yes No NA NE
Type of system ? Liquid
Page# 6

Permit: NCO028916 Owner -Facility: TroyWWrP
Inspection Date: 09/17/2019 Inspection Type: Compliance Sampling
De -chlorination
Yes. No NA NE
Is the feed ratio proportional to chlorine amount (1 to 1)?
0
:❑
❑ ❑
Is storage appropriate for cylinders?
❑
❑
0 ❑
# Is de -chlorination substance stored away from chlorine containers?
M
El
❑ ❑
Comment:
Are the tablets the proper size and type?
Are tablet de -chlorinators operational?
Number of tubes in use?
Comment:
❑ ❑ ■ ❑
❑ ❑ M ❑
Disinfection -Liquid
Yes No NA NE
Is there adequate reserve supply of disinfectant?
❑
❑
❑
(Sodium Hypochlorite) Is pump feed system operational?
.❑
:❑
❑
Is bulk storage tank containment area adequate? (free of leaks/open drains)
M
❑
❑
❑
Is the level of chlorine residual acceptable?
0
❑
❑
❑
Is the contact chamber free of growth, or sludge buildup?
M.
❑
❑
❑
Is there chlorine residual prior to de -chlorination?
M
❑
❑
❑
Comment:
Influent Sampling
Yes No NA NE
# Is composite sampling flow proportional?
❑
❑
0
❑
Is sample collected above side streams?
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
M'
❑
❑
❑
Celsius)?
Is sampling performed according to the permit?
M
❑
❑
❑
Comment:
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
❑
❑
❑
Is sample collected below all treatment units?
❑
❑
0
Is proper volume collected?
❑
❑
0
Is the tubing clean?
❑
❑
Page#
7
i

Permit: NCO028916 Owner -Facility: Troy WWTP
Inspection Date: 09/17/2019 Inspection Type: Compliance Sampling
Effluent Sampling Yes No NA NE
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ■ ❑ ❑ ❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type 0 ❑ ❑ ❑
representative)?
Comment:
Equalization Basins
Yes No NA NE
Is the basin aerated?
❑
❑
0
❑
Is the basin free of bypass lines or structures to the natural environment?
❑
N
❑
❑
Is the.basin free of excessive grease?
❑
❑
❑
Are all pumps present?
❑
❑T
❑
M
Are all pumps operable?
❑
❑
❑
Are float controls operable?
❑
❑
❑
Are audible and visual alarms operable?
❑
❑
❑
# Is basin size/volume adequate?
❑
❑
❑
Comment: Facility has a 10-Acre EQ Basin that sufferered a breach during Hurricane Florence that has
not been repaired. .
Standby Power
Yes No NA NE
Is automatically activated standby power available?
N
❑
❑
❑
Is the generator tested by interrupting primary power source?
N
❑
❑
❑
Is the generator tested under load?
0
❑
❑
❑
Was generator tested & operational during the inspection?
❑
❑
❑
.0
Do the generator(s) have adequate capacity to operate the entire wastewater site?
0
❑
❑
❑
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
❑
❑
❑
Is the generator fuel level monitored?
E
❑
❑
❑
Comment:
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