NC0025453-Pretreatment Compliance Inspection-20210819

ROY COOPER.
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Ms. Dolores Gill
Deputy Town Manager
Town of Clayton
P.O. Box 879
Clayton, NC 27520
NORTH CAROLINA
Environmental Quality
August 19, 2021
Subject: Pretreatment Compliance Inspection
Town of Clayton
NPDES Permit No. NC0025453
Johnston County
Dear Ms. Gill:
On July 9, 2021, Cheng Zhang of the Raleigh Regional Office conducted a Pretreatment
Compliance Inspection (PCI) of the program at Town of Clayton. The assistance given by Mr.
Bill Simpson, the wastewater operations superintendent, was greatly appreciated. The inspection
report is attached. Findings during the inspection were as follows:
1. There are three Significant Industrial Users (SIUs), which are also Categorical Industrial
Users (CIUs). It was noted that none of the SIUs was in Significant Non -Compliance
(SNC) during the two most recent six-month periods.
2. The pretreatment inspection file review included Novo Nordisk (Permit No. 0003-02),
Novo Nordisk DAPI (Permit No. 0002-05), and Grifols (Permit No. 0001-02). The files
needed for review were available, contained all required elements. During the second six-
month period of 2020, Novo Nordisk and Grifols were in compliance. Novo Nordisk
DAPI had multiple violations for pH, COD, BOD, and TDS, enforcement was taken
against these violations, as required by the Town's Enforcement Response Plan.
3. A review of the files containing the pretreatment program elements was conducted.
These files were well organized and up to date. The approval letter from the Division for
the Town's Enforcement Response Plan could not be located. A copy of the letter was
provided to Mr. Simpson via email on August 18, 2021.
4. The review of Long Term Monitory Plan data indicated that all locations were sampled
with required frequencies since the last inspection.
NOR�D_E
�aearbnenl al Environmental 9uallly
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

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]).
Sincerely,
-DocuSigned by:
%J tt,SStL le. (/Iow,L
B2916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Enclosure: Town of Clayton PCI Inspection Form
Cc: Central Files (Laserfiche)
Bill Simpson, Town of Clayton (electronic copy only)
1:11
NORTH CAROLINA
Ilea»vm or enw.mnmenteiau.rm\
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office r 3800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

N NORTH CAROLINA DIVISION OF WATER RESOURCES
ETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL QUALITY
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority (POTW) Name: Town of Clayton
2. Control Authority Representative(s): William Simpson
3. Title(s): Water Reclamation Superintendent
4. Last Inspection Date: June 6, 2019 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: Are Milestone Dates Being Met? ❑ YES ❑ NO
ICIS CODING
Main Program Permit Number
NICI0 10 1 2 1 5 1 4 1 5 1 3 I
MM/DD/YY
L 07 109 121 I
7. Current Number Of Significant Industrial Users (SIUs)?
3
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 SIUs on Schedules?
0
15. Current Number Of Categorical Industrial Users (CIUs)?
3
16. Number of CIUs 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?
/1 YES ❑ NO
5/27/2021 DO was 5.8 mg/L
❑ YES // NO
Limits: None
Reporting: None
lished: None
None
❑ YES /1 NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES
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? ® 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:
❑ NO
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 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 (HWA)
4/3/2017
0 Yes ❑ No
6/23/2017
r Yes ❑ No
4/1/2022
Industrial Waste Survey (IWS)
9/26/2018
' Yes ❑ No
10/31/2018
/1 Yes ❑ No
10/01/2023
Sewer Use Ordinance (SUO)
1/4/2013
/1 Yes ❑ No
1/11/2013
/1 Yes ❑ No
Enforcement Response Plan (ERP)
2/14/2020
/1 Yes ❑ No
3/17/2020
❑ Yes /1 No
Long Term Monitoring Plan (LTMP)
4/3/2017
a Yes ❑ No
6/20/2017
/1 Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION
29. User Name 1. Novo Nordisk 2. Grifols
3. Novo Nordisk DAPI
30. IUP Number
0003-02
0001-02
0002-05
31. Does File Contain Current Permit?
/1 Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
32. Permit Expiration Date
6/30/2022
6/30/2022
6/30/2022
_1
439.40
439.20
439.A
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
/1 Yes ❑ No
a Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
A Yes ❑ No
/1 Yes ❑ No
A 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. ►E Yes ■ No
b. •Yes ■No
a. ►E Yes ■ No
b. ■Yes ■No
a. 1 Yes ■ No
b. •Yes ■No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. ►EYes ■No
b.❑Yes❑No❑N/A
a. ►EYes ■No
b.❑Yes❑No❑N/A
a. 1Yes ■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?
A Yes ❑ No
/1 Yes ❑ No
A Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ No
/1 Yes ❑ No
I 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 I
J
®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/A1
EYcs❑No❑N/A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes ONO EN/A
NYes❑No❑N/A
®Yes❑No❑N/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Ycs❑NoNN/A
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
❑Yes❑NoEN/A
❑Yes❑NoNN/A
❑Yes❑No❑N/A
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑Yes❑NoEN/A
❑Yes❑NoNN/A
EYes❑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
a.❑Yes❑No®N/A
b.❑Yes❑NoDN/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 ❑NoDN/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 /1 No 0
❑ Yes r No II
❑ Yes I No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
❑Yes❑NoEN/A
❑Yes❑NoNN/A
EYes❑No❑N/A
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoEN/A
❑Yes❑NoNN/A
❑Yes❑NoEN/A
50. a. Does the 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
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
❑ Yes /1 No
❑ Yes L No
❑ Yes /1 No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

FILE REVIEW COMMENTS:
41b - Grifols reports monthly flow, Clayton does all sampling.
43a - Novo DAPI had multiple pH (July), COD, BOD, TDS (August), two NOVs were issued for these violations.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
J I 1 L I I L
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:
OVERALL SUMMARY AND COMMENTS:
Comments: The program is well managed.
Requirements: None
Recommendations: None
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
® Satisfactory ❑ Marginal ❑ UnSatisfactory
PCI COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: July 9, 2021
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3