NC0063096_Pretreatment Compliance Inspection_20161019

Water Resources
ENVIRONMENTAL QUALITY
October 19, 2016
Mr. Seann Byrd
Public Utilities Director
Town of Holly Springs
P.O. Box 8
Holly Springs, NC 27540
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
secretary
S. JAY ZIMMERMAN
Director
RECEIVEDUD OIDWR
OCT 2 4 2016
Water Quality
Subject: Pretreatment Compliance Inspection 9-11rnittiny Section
Town of Holly Springs
Utley Creek WWTP­ NPDES Permit No. NCO063096
Wake County
Dear Mr. Byrd:.
On September 12, 2016, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a
Pretreatment Compliance Inspection of Town of Holly Springs' pretreatment program. The
assistance given by Ms. Amy -Moore, the lab manager and pretreatment coordinator, was greatly
appreciated. The inspection report is attached. Findings during the inspection were as follows:
1. Town of Holly Springs has two Significant Industrial. Users (SIUs), one of which is also
Categorical Industrial Users (CIUs). Itvas noted that neither SIU was in SNC during the
two most recent semi-annual periods.
2. The pretreatment inspection file review included Novartis Vaccine and Diagnostic
(Permit No. 002), and South Wake Landfill (Permit No. 0.01). The files needed for review
were available for inspection, contained all the required elements and were in excellent
condition.
3. The POTW and both SIUs completed monitoring as required by the IUPs during the first
semi-annual period of 2011, both SIUs were in compliance.
4. A review of the files containing the pretreatment program elements was conducted.
Updates for Headworks Analysis (HWA) and Industrial Waste Survey (IWS) are due on
December 31, 201`6 and September 30, 2016, respectively.
5. , LTMP data were reviewed during the inspection. It was noted that all locations were
sampled with required frequencies and all samples analyzed with required detection
levels since the last inspection.
Division of Water Resources, Raleigh Regional Office, Water Quality Operations Section bttp:Hdeq.nc.gov/about/divisions/water-resources
1628 Mail Service Center, Raleigh, NC 27699-1628 Phone: [phone]
Location: 3800 Barrett Drive, Raleigh, NC 27609 Fax: [phone]

Town of Holly Springs' pretreatment Program is well managed. Thank you for your continued
support of the Pretreatment Program. If you have any questions or comments, please call Cheng
Zhang at [phone] (or email: [e-mail]).
t
cerel a12
my Sr
Regional Supervisor
Raleigh Regional Office
Enclosure: Town of Holly Springs PCI Inspection Form
CC: Sarah Morrison Bass, PERCS Unit
Central Files
Cheng Zhang, RRO
Amy Moore, Town of Holly Springs

NORTH CAROLINA DIVISION OF WATER QUALITY
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION [Complete Prior To PCh Review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Holly Springs
2. Control Authority Representative(s): AM Moore
3. Title(s): Pretreatment Cooidinator/Laboratory Manager
4. Last Inspection Date:11/21/2013 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 ® NO
Order Type, Number, Parameters:
PCS CODING
Trans.Code Main Program Permit Number
I N I I N I C 1 0 1 0 1 61 31 01 9 161
Are Milestone Dates Being Met? ❑ YES ❑ NO
MM/DD/YY Inspec.Type Inspector Fac. Type
109 1 121 16-1 I P I L _SJ
L-1 J
FACCI
—' (DTIA) (TYPI) (INSF)
(
7. Current Number Of Significant Industrial Users (SIUs)? 2
SNS
8. Current Number Of Categorical Industrial Users CIUs ? 1
CNS
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. Enter the Higher Number of 9 or 10
0
NOIN
12. Number of SIUs With No IUP, or With an Ex iced IUP
0
NOCM
13. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2
0
PSNC
Semi -Annual Periods Total Number of SIUs in SNC)
14. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods
0
MSNC
15. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods
0
SNPS
16. Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2
0
Semi-annual Periods
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 SNC for
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC foi
Public Notice?(May refer to PAR if Excessive SIUs in SNC) 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?
ElYES ® NO
ElYES ®NO
Limits: None
Reporting: None
)fished: None
None
ElYES ® 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 [:1NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? ® YES E]NO Is Table Adequate? ® YES ElNO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ® YES E]NO DWQ Inspector, please verify
yourselfl
26. If NO to 23 - 26, list violations
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ElYES 0 NO
If yes, which ones? Eliminated: Added:
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program
Element in 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 A)
10/10/2012
® Yes ❑ No
1/18/2013
® Yes ❑ No
12/31/2016
Industrial Waste Survey S)
8/16/2013
® Yes ❑ No
11/14/2013
® Yes ❑ No
9/30/2016
Sewer Use Ordinance SUO
11/8/2012
® Yes ❑ No
12/7/2012
® Yes ❑ No
® Yes ❑ No
Enforcement Response Plan RP
6/22/2010
® Yes ❑ No
8/4/2010
® Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
Long Term Monitoring Plan (LTMP) 1
1/29/2014
® Yes ® No
2/3/2014
® Yes ❑ No
a. ®Yes [--]No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. South Wake Landfill 2. Novartis
3.
30. IUP Number
001
002
31. Does File Contain Current Permit?
® Yes El No
®Yes [:1 No
El Yes El No
32. Permit Expiration Date
1 12/31/2018 11
12/31/2017
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
I N/A
439
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
® Yes ❑ No
❑ Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
® Yes ❑ No
®Yes [:1 No
❑Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
a. ®Yes ❑No
a. ®Yes [--]No
a. ❑Yes ❑No
b. If No, is One Needed? (See Inspection Form from POTW)
I b. ❑Yes ❑No 11
b. ❑Yes ❑No
b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No❑N/A
Organic Management Plan (TOMP)?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes ❑Noa.
ll
®Yes ❑No
a. []Yes❑No
b. All Issues Resolved?
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑ No
® Yes ❑ No]1
❑ Yes ❑ No
its Sampling as Required by IUP, includin flow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
I ® Yes ❑ No
® Yes ❑ No 11
❑ Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Yes❑No❑N/A
11
®Yes❑No❑N/A
❑Yes❑No❑N/A
Sampling as Required by IUP, including flow?
1
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
®Yes❑No❑N/A
!75N—oo
❑Yes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
®Yes❑No❑N/A
❑Yes❑No❑N/A
file include process/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
1 11
❑Yes❑NoNN/A
❑Yes❑No❑N/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑No®N/A
❑Yes❑NoON/A
❑ Yes ❑ No
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NOON/A
❑Yes❑No®N/A
❑Yes❑No❑N/A
All Reportine Non -Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑No®N/A
a.❑Yes❑No®N/A
a.❑Yes❑No❑N/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
c. If applicable, Did POTW resample within 30 days of becoming aware
c.❑Yes❑No®N/A
cYes❑No®N/A
.❑
c.❑Yes❑No❑N/A
of SIU limit violations in the POTW's sampling of the SIU?
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes ® No
I ❑ Yes ® No 11
❑ Yes ❑ No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑No®N/A
11
❑Yes❑No®N/A
❑Yes❑No❑N/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoNN/A
❑Yes❑No®N/A
❑Yes❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑Yes❑NoUN/A
❑Yes❑No❑N/A
50. a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑NonN/A
a.❑Yes❑No®N/A
a.❑Yes❑No❑N/A
b. Is SIU in Compliance with Order?
b.❑Yes❑MUN/A
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ® Ko
® No
❑ Yes ❑ No
Requested Information For You?
][7Z
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

I.,
FILE REVIEW COMMENTS:
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type
rr l J J -� 1 I I J.. I l L S-1 1? - l
(DTIA) (TYPI) (INSP) (FACC)
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? 0 YES 0 NO
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview DYES ❑ NO
B. Plant Tour DYES ❑ NO
C. Pretreatment Tour 0 YES ❑ NO
D. Sampling Review 0 YES ❑ NO
E. Exit Interview 0 YES ❑ NO
Industrial Inspection Comments:
OVERALL SUMMARY AND COMMENTS:
Comments: The pretreat Program is well managed and in compliance
Requirements:
Recommendations:
NOD: 0 YES ®NO
NOV: 0 YES 0 NO
QNCR: 0 YES ® NO
POTW Rating:
Satisfactory ® Marginal 0 UnSatisfactory 0
PCI COMPLETED BY: Cheng Zhang DATE: September 12, 2016
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3