NC0025453_Pretreatment Audit_20221206

DocuSign Envelope ID: 5DAC8295-9748-45D3-9A5E-D7191E5E4512
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
Certified Mail # 7020 3160 0000 4115 5030
Return Receipt Requested
December 6, 2022
Mr. Rich Cappola
Town Manager
Town of Clayton
P.O. Box 879
Clayton, NC 27520
Subject: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Case No. NOV-2022-PC-0739
Pretreatment Audit
Town of Clayton
Sam's Branch Water Reclamation Facility - NPDES Permit No. NC0025453
Johnston County
Dear Mr. Cappola:
On September 9, 2022, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a compliance
audit of Town of Clayton's pretreatment program. The assistance given by Mr. Bill Simpson, the
wastewater operations superintendent, and Salvador Valdiviezo Jr., the senior operator, was
greatly appreciated. The inspection report is attached. Findings during the inspection were as
follows:
1. The Town has three Significant Industrial Users (SIUs), all are also Categorical Industrial
Users (CIUs). It was noted that Novo Nordisk DFP might have been in Significant Non-
compliance (SNC) for reporting violation (failure to report parameters required by
its Industrial User Permit (IUP)) in the first semi-annual period of 2022.
2. A review of the files containing the pretreatment program elements was conducted. Town
of Clayton was found to have violated Section D, 4 of its NPDES permit for failure to
submit update of Headworks Analysis before the due date, which was April 1, 2022.
Long Term Monitoring Plan (LTMP) needs to be updated by using the most recent
PQLs.
3. Long Term Monitoring Plan (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.
NORTH CAROLINA
o.y,ror.m 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: 5DAC8295-9748-45D3-9A5E-D7191E5E4512
4. The pretreatment inspection file review included Novo Nordisk DFP (Permit No. 0003-02)
Grifols (Permit No. 0001-02), and Novo Nordisk DAPI (Permit No. 02-0005). During the
most recent semi-annual period:
• Town of Clayton was found to have violated 15A NCAC 02H .0916 (c) (5) for
failure to renew IUPs for Novo Nordisk DFP and Novo Nordisk DAPI before the
IUPs expired on June 30, 2022.
• The POTW was found to have violated Section D, 9 of its NPDES permit for
failure to identify and take enforcement actions against limit violations
(Grifols and Novo Nordisk DAPI) and reporting violation (Novo Nordisk DFP).
• Grifols IUP was renewed, the POTW needs to submit the IUP to the division for
revies and approval.
5. During the audit, Mr. Simpson and Mr. Valdiviezo inspected the lone SIU, Newton
Instrument. The inspection was very thorough and covered all required areas.
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North
Carolina General Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S.
143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be
assessed against any person who violates or fails to act in accordance with the terms, conditions,
or requirements of any permit issued pursuant to G.S. 43-215.1.
Please respond in writing to RRO within 30 days of receipt of this letter regarding Items 1, 2
and 4. If you have any questions or comments, please call Cheng Zhang at [phone] (or
email: [e-mail]).
Sincerely,
DocuSigned by:
Fhwu,ssa f, ilk
B2916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Enclosure: Town of Clayton Pretreatment Audit Form
CC: Laserfiche
Bill Simpson, Town of Clayton (Electronic copy only)
D_E
NORTH CARCLINA
gaparhnanl of Environmental quality
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: 5DAC8295-9748-45D3-9A5E-D7191E5E4512
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 Clayton, Sam's Branch Water Reclamation Facility
2. Control Authority Representative(s): William Simpson and Salvador Valdiviezo Jr.
3. Title(s): Wastewater Operations Supervisor, Senior Operator
4. Address of POTW:
Mailing 1000 Durham St. Ext., P.O.Box 879
City Calyton, NC Zip Code 27528
Phone Number [phone] Fax Number [phone] E-Mail wsimpsonnn,townofclaytonnc.org
5. Audit Date 9/9/2022
6. Last Inspection Date: 7/9/2021 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. Two DO violations in July 2021.
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
INICIOI0I2 I5 I4 I5 I3I
10. Current Number of Sivnificant Industrial Users (SIUs)?
11. Number of SIUs with No IUP, or with an Expired IUP?
MM/DD/YY
09 09 22 I
3
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?
3
0
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 1

DocuSign Envelope ID: 5DAC8295-9748-45D3-9A5E-D7191E5E4512
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)
4/3/2017
01 Yes ❑ No
6/23/2017
0 Yes ❑ No
4/1/2022
Industrial Waste Survey (IWS)
9/26/2018
II Yes ❑ No
10/31/2018
I: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
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
4/3/2017
0 Yes ❑ No
6/20/2017
/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. I-40/NC 42 area, sending wastewater (1.44 MGD, mostly industrial)
to Johnston County. Starting in 2018, sending wastewater to City of Raleigh at 1.75 MGD for the next ten years.
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. Need to send IJAs to the 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 4/1/2013
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 Followine: S=Satisfactory M=Marginal U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
e S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
/1S ❑M ❑U
Access to Operable Sampling
Equipment
/1S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
0 S ❑M ❑U
Reference Materials
0S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
/1S ❑M ❑U
Computer Equipment (Hardware and
Software)
/1S ❑M ❑U
NC DWR Pretreatment Audit Form
Revised: December 2016
Page 2

DocuSign Envelope ID: 5DAC8295-9748-45D3-9A5E-D7191 E5E4512
30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Excel spreadsheet. Will switch to Allmax shortly.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Sampling fees, surcharge for BOD, TSS, and COD; AtoC cost.
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? Any data but confidential is allowed to be reviewed.
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? The Town has developed agreement to keep trade secrets
confidential.
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
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? Whenever a new sewer account is established, the user
needs to fill out industrial short form, and if needed, long form.
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?) Categorical, discharge exceeds 5% of MAHL, or daily flow more than 25000 gallons
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
Yes No If Yes, How many are there?
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)
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. Currently not taking any flow from SIUs.
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)
Based upon the contribution to wastestream and historical performance; categorical limits.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 3

DocuSign Envelope ID: 5DAC8295-9748-45D3-9A5E-D7191 E5E4512
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Based upon potential to exceed permit limits, and what is specified in IJAs.
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. Enter monthly data into spreadsheet, violations will be highlighted.
Every six month, review data of compliance points to judge whether the industry is in 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.
54. What criteria are used to determine if a slug/spill control plan is needed?
Based on inspection of hazardous chemicals usage and storage and potential to spill.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Problem points identified and contained, adequate notification procedure.
56. How does the POTW decide where the sample point for an SIU should be located?
Based on process, prior to leave the property.
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. Instruction on samplers and COSs.
58. Who performs sample analysis for the POTW for Metals Environmental One
Conventional Parameters Environmental One
Organics Environmental One and Cameron
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Use standard COC's provided by contract labs.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ 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 ❑ NO Is Table Adequate? ® YES ❑ NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ 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? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
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 ❑Sludge Quality
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ® Yes ❑ No
Explain. Sludge will be composted, construct a new treatment plant.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 4

DocuSign Envelope ID: 5DAC8295-9748-45D3-9A5E-D7191E5E4512
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
Construction of new treatment plant.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 5

DocuSign Envelope ID: 5DAC8295-9748-45D3-9A5E-D7191E5E4512
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Novo Nordisk DFP
2. Grifols
3. Novo Nordisk DAPI
67. IUP Number
0003-02
0001-02
02-0005
68. Does File Contain Current Permit?
0 Yes ❑ No
0 Yes ❑ No
A Yes ❑ No
69. Permit Expiration Date
6/30/2022
12/31/2024
6/30/2022
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
439.40
439.26
439A
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
/1 Yes ❑ No
0 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 ■No
a. ►Yes •No
b. •Yes ■No
a. •Yes •No
b. •Yes ■No
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 rNo
b.❑Yes❑No❑N/A
a. •Yes ONo
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
0 Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
Al Yes ❑ No
/1 Yes ❑ No
/1 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 ❑No❑N/A
❑Yes❑NoON/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 ❑NOON/A
❑ Yes ❑NoON/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 ®No❑N/A
❑ Yes 0 No
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting_Non-Compliance from SIU Sampling?
❑Yes®No❑N/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❑NOON/A
b.❑Yes❑No®N/A
❑ c.Yes❑No®N/A
a.®Yes ❑No❑N/A
b.El 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®No❑N/A
❑ Yes ®No❑N/A
®Yes❑No❑N/A
86. Does File Contain Penalty Assessment Notices?
❑Yes❑No ON/A
❑Yes❑NoON/A
❑Yes❑NoNN/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑N°ON/A
❑ Yes ❑NoON/A
❑Yes❑NoON/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❑NOON/A
b.❑Yes❑No®N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information for You?
i1 Yes ❑ No
i1 Yes ❑ No
A Yes ❑ No
FILE REVIEW COMMENTS:
69 - Novo Nordisk DFP and Novo Nordisk DAPI's IUPs expired on 6/30/2022, POTW failed to renew them before expiration (Novo Nordisk
DFP did not submit renewal application). Grifols' IUP was renewed (effective 9/8/2022), the IUP has not been reviewed by the Division.
78 & 82 - Novo Nordisk DFP only reported flow, pH, and temperature during the first 6-month period of 2022.
81 - POTW failed to identify and take enforcement action against limit violations from Grifols and Novo DAPI.
84 - Novo Nordisk DFP might be in SNC for reporting violation.
NC DWR Pretreatment Audit Form Revised: December 2016
Page 6

DocuSign Envelope ID: 5DAC8295-9748-45D3-9A5E-D7191E5E4512
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number
INICI0I0I2 15 14 15 13I
MM/DD/YY
109 109 122
1. Industry Inspected: Novo Nordisk DAPI
2. Industry Address: 3611 Powhatan Rd., Clayton, NC 27527
3. Type of Industry/Product: Pharmaceutical / Insulin
4. Industry Contact: Jessie Darby Title: Environmental Coordinator
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: Failure to renew IUPs for Novo Nordisk DFP and DAPI. Failure to identify and take enforcement action
against violations from SIUs. Failure to submit update of Headworks Analysis (HWA) before the due date.
Requirements: Renew Novo IUPs as soon as possible. Submit Grifols' IUP to the Division for review and approval. Submit update
of HWA before the new due date should the Division grant an extension. Take enforcement actions against SIU violations. Decide
whether Novo Nordisk DFP is in SNC for reporting violation (revised report received with missing parameters?)
Recommendations: Update LTMP by using most recent PQLs for As, Cd, CN, Pb, Ni, and Se.
NOD: ❑ Yes ® No
NOV: ® Yes ❑ No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ❑
Marginal ❑ Unsatisfactory
Audit COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: September 9, 2022
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 7