NC0063096_Pretreatment Audit_20221130

DocuSign Envelope ID: 3037D3B3-B35A-491 E-AA56-79289043EC3B
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. Seann Byrd
Water Resources Director
Town of Holly Springs
P.O. Box 8
Holly Springs, NC 27540
NORTH CAROLINA
Environmental Quality
November 30, 2022
Subject: Pretreatment Audit Inspection
Program: Town of Holly Springs
Wake County, NPDES #: NC0063096
Holly Springs WWTP
Dear Mr. Byrd:
Enclosed please find a copy of the Pretreatment Audit Inspection form from the inspection conducted on
September 2, 2022. The Pretreatment Audit Inspection was conducted by Cheng Zhang, Environmental
Specialist II, of the Raleigh Regional Office. The assistance given by Ms. Karen Foster, the
Environmental Compliance Manager, was greatly appreciated.
The purpose of the pretreatment audit is to determine the effectiveness of the Pretreatment Program by
reviewing the files, which include a review of POTW plant performance, sampling and compliance
judgment program, adherence to the enforcement response plan (ERP), and evaluating how the program
performs an industrial user inspection.
The audit report is attached with findings and observations made during the inspection. Please review for
more detail.
Background
The Town of Holly Springs has two (2) significant industrial users (SI Us), one (1) of which is
categorical under 40 CFR 439 (Pharmaceutical). The Holly Springs WWTP is a 6.0 MGD permitted
facility.
Industrial User Permit (IUP) File Review
Two permit files were reviewed. The pretreatment audit file review included South Wake Landfill and
Novartis Vaccines & Diagnostics. Files were well organized and there was no difficulty finding any of
the requested information. Copies of the facilities' spill control plans are on file.
Industrial Inspection
NORTH CAROLINA
oay,rorem or Environmental ou.i�
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office I 3800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: 3037D3B3-B35A-491 E-AA56-79289043EC3B
A thorough inspection was conducted at South Wake Landfill. All components of the inspection form
were covered.
Long Term Monitoring Plan (LTMP)
The Town submitted update of LTMP on August 31, 2022, and a revised version on September 7, 2022
(with updated PQLs for some parameters), the LTMP was approved by the Division on September 12,
2022.
Headworks Analysis (HWA)
Update of HWA was submitted to the Division on September 14, 2022, which was due September 15,
2022.
This Audit report indicates that the Town of Holly Springs' Pretreatment Program meets the
pretreatment requirements as outlined in 15A NCAC 2H .0900 and 40 CFR 403 and the inspection is
satisfactory and in compliance. Ms. Karen Foster is implementing the Pretreatment Program in a
consistent and professional manner and her assistance during the inspection is greatly appreciated.
Thank you for your continued cooperation with the Pretreatment Program. Please do not hesitate to
contact Cheng Zhang at 919-791-4259 [[e-mail]] if you have any questions or
concerns. program.
Enclosure: 2022 Holly Springs PT Audit Form
CC: Laserfiche
Karren Foster, Town of Holly Springs (electronic copy only)
D_E
NORTH CARCLINA
gaparhnanl of EnWrnmmonfal wary
Sincerely,
DocuSigned by:
bL1tss
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B2916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

DocuSign Envelope ID: 3037D3B3-B35A-491E-AA56-79289043EC3B
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resources
ENVIRONMENTAL QUALITY
Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Holly Springs, Holly Springs WWTP
2. Control Authority Representative(s): Karen Foster
3. Title(s): Utilities Manager- Environmental Compliance
4. Address of POTW:
Mailing PO Box 8
City Holly Springs Zip Code 27540
Phone Number 919-557-2907 Fax Number 919-577-2280 E-Mail karen.foster(i/hollyspringsnc.gov
5. Audit Date 9/2/2022
6. Last Inspection Date: 9/4/2020 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ❑ Yes ® No
If Yes, Explain.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number
INICI0I0I6I3 I0 I9 I6I
10. Current Number of Sivnificant Industrial Users (SIUs)?
11. Number of SIUs with No IUP, or with an Expired IUP?
MM/DD/YY
09 02 122 I
2
0
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
0
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
0
14. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
0
15. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
0
16. Number of SIUs in SNC with Pretreatment Schedule?
0
17. Number of SIUs on Schedules?
0
18. Current Number of Categorical Industrial Users (CIUs)?
19. Number of CIUs in SNC?
2
0
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 1

DocuSign Envelope ID: 3037D3B3-B35A-491E-AA56-79289043EC3B
20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element
in their File, complete with all supporting documents and 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)
9/14/2022
01 Yes ❑ No
2/23/2018
0 Yes ❑ No
9/15/2022
Industrial Waste Survey (IWS)
9/30/2021
I4 Yes ❑ No
6/2/2022
I:1 Yes ❑ No
1/31/2027
Sewer Use Ordinance (SUO)
11/8/2012
/1 Yes ❑ No
127/2012
/1 Yes ❑ No
Enforcement Response Plan (ERP)
6/22/2010
/1 Yes ❑ No
8/4/2010
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
8/31/2022
a Yes ❑ No
9/12/2022
/1 Yes ❑ No
Legal Authority (Sewer Use Ordinance-SUO)
21. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
❑ Yes ® No If yes, Please list these towns and/or areas.
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑ Yes ❑ No ® NA
A copy, if not already submitted, should be sent to Division.
23. If yes to #21, Have you had any trouble working with these towns or districts? ❑ Yes ❑ No ® NA
If yes, Explain.
24. Date of Last SUO Adoption by Local Council 11/6/2012
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? ❑ Yes ❑ No
If no, POTW must send copy within 30 days.
27. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
❑ Yes ® No If yes, Explain.
28. List Industries under a Schedule or Order and Type of Schedule or Order
None
Resources
29. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
a S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
/1 S ❑M ❑U
Access to Operable Sampling
Equipment
OS ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
a S ❑M ❑U
Reference Materials
►1S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
a S ❑M ❑U
Computer Equipment (Hardware and
Software)
a S ❑M ❑U
NC DWR Pretreatment Audit Form
Revised: December 2016
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DocuSign Envelope ID: 3037D3B3-B35A-491E-AA56-79289043EC3B
30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Excel spreadsheet. Plans to upgrade to Utility Cloud or Linko.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Surcharge for BOD, TSS, TN, TP, NH3 based on exceeding domestic levels. Also, annual fee, permit fee and sampling fee.
Public Perception/ Participation
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain.
33. Has any one from the public ever requested to review pretreatment program files? ® Yes ❑ No
If yes, Explain procedure. If no, how would the request be addressed? Several years ago requests for copies of HWA. Copies
were provided. Any requests would be handled in the same manner.
34. Has any industry ever requested that certain information remain confidential from the public? ❑ Yes ❑ No If yes, Explain
procedure for determining whether information qualified for confidential status, as well as procedure for keeping files confidential
from public. If no how would the request be addressed? Made sure that the information was proprietary to their process and
keeps information in a separate file.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No Announced on Council docket
37. Were all industries in SNC published in the last notice? ❑ Yes ❑ No ® NA
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? Every new business receives a development package
which includes a short form survey to complete and return.
39. Once the POTW becomes aware of new or changed Users, how does the POTW determine which industries have the
reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an
SIU?) SIC codes, type of industry (categorical or potential to impact) water usage.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes ENo If Yes, How many are there? Landfill is permitted as SIU. Also, a small groundwater remediation
project for gasoline contamination, and Red Rock C&D Landfill, neither are active.
Please list each site and how it is permitted, if applicable.
41. Does the POTW accept waste by (mark if applicable) ❑ Truck ❑Dedicated Pipe ® NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) ® NA
43. How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits ® Historical Industry Need ❑ By Surcharge ® Categorical Limits ❑ Other
Explain Other:
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ❑ Yes ® No
If yes, what parameters are over allocated?
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter 20%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
48. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (for example: were only those pollutants
listed on the application limited; categorical parameters; NPDES Pollutants of Concern)
Limits for everything POTW has limits for, categorical parameters, monitoring for metals and priority pollutant scan
I/year
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 3

DocuSign Envelope ID: 3037D3B3-B35A-491E-AA56-79289043EC3B
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Based on impact to WWTP. Landfill 2/month because of variability of loading. Novartis 1/month generally more
consistent.
Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No
If yes, which industries? What was (will be) the outcome of the adjudication?
51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC. Each month reports submitted by 20th day of month - does send
NOVS if no 24-hour notice. Results are compared to permit limits. If there are violations contacts SIU, refers to ERP. Uses
compliance judgement worksheet for semi-annual SNC.
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all Division data? ❑ Yes ❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes ❑ No
If no, Explain. Both have one. Asks at inspection if any updates. Novartis makes frequent updates POTW information is
posted for notification.
54. What criteria are used to determine if a slug/spill control plan is needed?
Looks for drains, plumbing where chemicals are stored or used. Potential impact to POTW from accidental discharge.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Review at inspection: what actions are taken, how do staff know who to contact.
56. How does the POTW decide where the sample point for an SIU should be located?
At SIU discharge (process wastewater only) prior to connection to collection system.
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: ® Yes ❑ No SIU: ® Yes ❑ No If yes, Explain. Inspects equipment; both have lsco samplers.
Novartis is field certified. Has watched them collect samples.
58. Who performs sample analysis for the POTW for Metals Meritech+ Enthalpy (PFAS)
Conventional Parameters In-house+Meritech
Organics Meritech+Enthalpy
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Bench sheet of pH and temperature (same as used in plant). Has calibration info., start and stop times. Commercial lab has
own COC.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES El NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES El NO Is Table Adequate? ® YES El NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES El NO Division Inspector, verify yourself!
60e. If NO to any above, list violations
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? El YES ® NO
If yes, which ones? Eliminated: Added: recently As, Se, Ag, Hg, Mo
61. Do you complete your own headworks analysis (HWA) ? ® Yes ❑ No
If no, who completes your HWA? Phone ( ) --
62. Do you have plans to revise your HWA in the near future? ® Yes ❑ No
If yes, what is the reason for the revision? (mark all that apply) ❑Increased average flow ❑NPDES limits change
❑More LTMP data available ❑Resolve over allocation ®5 year expiration ['Other
Explain.
63. In general, what is the most limiting criteria of your HWA? ❑Inhibition ® Pass Through El Sludge Quality
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 4

DocuSign Envelope ID: 3037D3B3-B35A-491E-AA56-79289043EC3B
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ® Yes ❑ No
Explain. Future plant upgrade/expansion.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
More staff, two new SIUs, and plant upgrade.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 5

DocuSign Envelope ID: 3037D3B3-B35A-491E-AA56-79289043EC3B
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. South Wake Landfill
2. Novartis
3.
67. IUP Number
001
002
68. Does File Contain Current Permit?
0 Yes ❑ No
0 Yes ❑ No
❑ Yes ❑ No
69. Permit Expiration Date
12/31/2023
12/31/2022
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
439.17&47
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
/1 Yes ❑ No
❑ Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
/1 Yes ❑ No
❑ Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. ►Yes •No
b. ■Yes MN()
a. ►Yes •No
b. •Yes MN()
a. •Yes •No
b. •Yes MN()
Certification, Does File Contain a Toxic
(TOMP)?
❑Yes❑NoON/A
❑ Yes ❑No®N/A
❑Yes❑No❑N/A
74. For 40 CFR 413 and 433 TTO
Organic Management Plan
75. a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. ►Yes •No
b.❑Yes❑No❑N/A
a. ►Yes •No
b.❑Yes❑No❑N/A
a. •Yes •No
b.❑Yes❑No❑N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
Sampling as Required by IUP, including Flow?
0 Yes ❑ No
/1 Yes ❑ No
❑ Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
Al Yes ❑ No
/1 Yes ❑ No
❑ Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
Sampling as Required by IUP, including Flow?
®Yes❑No❑N/A
® Yes ❑No❑N/A
❑Yes❑No❑N/A
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
time?
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes❑No❑N/A
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑NoON/A
❑ Yes ❑NoON/A
❑Yes❑No❑N/A
80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑No®N/A
❑ Yes ❑No®N/A
❑ Yes ❑No❑N/A
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Limits Non -Compliance from Both POTW and SIU Sampling?
❑ Yes ❑NoON/A
❑ Yes ❑NoON/A
❑ Yes ❑ No
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting Non -Compliance from SIU Sampling?
❑ Yes ❑NoON/A
❑ Yes ❑NoON/A
❑Yes❑No❑N/A
83. a. Was 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 and obtain results within 30 days of
becoming aware of SIU limit violations in the POTW's sampling of SIU?
a.❑Yes❑No®N/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
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑ Yes 1 No
❑ Yes /1 No
❑ Yes ❑ No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
❑Yes❑NoON/A
❑ Yes ❑NoON/A
❑Yes❑No❑N/A
86. Does File Contain Penalty Assessment Notices?
❑Yes❑NoNN/A
❑ Yes ❑No0N/A
❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑No ON/A
❑ Yes ❑NoON/A
❑Yes❑No❑N/A
88. a. Does File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
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
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
❑ Yes A No
❑ Yes I1 No
❑ Yes ❑ No
FILE REVIEW COMMENTS:
Both SIUs were in compliance during the first semi-annual period of 2022.
NC DWR Pretreatment Audit Form Revised: December 2016
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DocuSign Envelope ID: 3037D3B3-B35A-491E-AA56-79289043EC3B
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number
IN I C 10I 01 6 1 3 1 0 1 9 1 61
MM/DD/YY
109 102 122
1. Industry Inspected: South Wake Landfill
2. Industry Address: 6000 Old Smithfield Road, Holly Springs, NC 27502
3. Type of Industry/Product: LandfilULeachate
4. Industry Contact: Seth Gundersen Title: Operations Supervisor 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:
The inspection is thorough and detailed.
Audit SUMMARY AND COMMENTS:
Audit Comments: The program is well managed.
Requirements: None
Recommendations: None
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory
Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: September 2, 2022
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 7