NC0025453_NOV-2022-PC-0709_20230117 Resp Rvcd 20230117

. •,. ittjnental Quality
MAYOR
Jody L. McLeod
IN'I'ERIMI TOWN MANAGER
Richard D. Cappola, Jr.
TOWN ATTORNEY Imo, j ,Y•rON
.t ,P
Cauley Pridgen, P.A.
Cheng Zhang
Environmental Specialist II
Water Quality Regional Operations Section
Raleigh Reginal Office
Division of Water Resources, NCDEQ
Mail Service Center 1628
Raleigh, NC 27609-1628
Subject: Response to NOV-2022-PC-0739
Mr. Zhang,
geo02 y53
1gb
JAN
Raleigh
January 11, 2023
1 7 2023
gional Office
MAYOR PRO TEM
.Jason "Thompson
COUNCIL MEMBERS
Anclria .Archer
Portcr Casey
Avery Eve ctt
Michael Sims
Please find the response to NOV-2022-PC-0739. As we discussed in our inspection the many reasons for these
violations. I want to make no excuse, as I am aware as an Operator of Responsible Charge the violations cast an
unfavorable reflection of myself in this role. I would like to point out that I have only held this position for the 14
Months. While I was Lab Supervisor, I only handled the field sampling and data entry until having to stumble through
the PAR reports in March of 2021. This is the first time with having to do the renewal process for the industries I was a
part of the process before this was all handled by James Warren. We lost a lot of experience with his retirement. Many
of these deficiencies are directly related to the lack of experience and the shifting of our responsibilities within the Town
of Clayton. July 7tn, I inquired with our HR department to fill the Lab Tech position and it was not until October 25th,
2021, the position was filled. Covid made filling positions very difficult, and workloads became very overwhelming.
In response to item 1,
I received a call from the contact at Novo DFP that a mix up in coolers had taken place on the first qtr. sampling. He
informed me that the sampling had been completed and the results would be received after the report date in his
permit. I informed him to submit what he had and make comments about having sampled and awaiting results to
submit an amended report later. The Town has verified that the sampling had taken place during the most recent
inspection. Please see attached.
In response to item 2,
Our Head work analysis had expired and was out of date as of April 1, 2022. The data to compile the Headworks
analysis was missing from our file that we use to calculate the headworks analysis. We have thought about the data
entry and multiple files with different information and the problem it creates. In FY 2022 the Town purchased a data
management software (ALLMAX). Upon installation on our 3`d party VOA system, it was found to not be as completable
as we thought it would be. We have ordered new Hardware for this system to reside on in FY2023 and are just waiting
for the antivirus software fort the new server.
PO Box 879 • Clayton, NC, 27528 • 919-553-5002
Think
LAYTO5T
.lIt,,.1,1«01,,.' Fax 9
9-553-8919 • TownofClaytonNC.org

PQL limits for the Long -Term Monitoring Plan have been checked and verified several times with our contract Lab
Environment 1 Inc. Please see the included Detection Limit Sheet Provided by the Lab in 2019.
In response to item 4
I make no excuse, I have just spread myself too thin and did not have the depth I thought I had in our current staff and
was not able to complete the HWA and get the draft packets to Pretreatment Group prior to Expiration and review data
as I was required. We do have drafts of the Permits with no Changes other than adding the Total Dissolved Solids as a
parameter to monitor more closely. We also are proposing a 24-month permit as we have and ATC at Grifols that is
going to be coming to substantial completion in late 2024. Johnston County which is where all our industrial flow is
currently flowing will be nearing completion and require some modifications to the current Interlocal Agreement to
ensure compliance at both facilities. We completed a sale of what was thought to become a regional pretreatment
facility to the sole source of its influent with Novo DAPI. Novo has also begun to review the Ultra -filtration and RO to
deal with TDS from its process discharge.
I have implemented reminders on my calendar. I have spoken with current Employees and tried to get them up to
speed with the demands of this Program. Launching of the $35,000 investment into an Operations and Pretreatment
Software to remove the amount of files used to prepare the Items needed to maintain a compliant pretreatment
program. I would also ask for time to help get a grasp on how our current program as it has been laid out and a chance
to adjust and acclimate to the systems in place. We continue to find files that seem to be out of place that could help
us. Many of the files have had compatibility issues when we open them with the updated windows products that
require some additional time. I have called and ask Keyes McGee with the Pretreatment unit to setup something and
come in and help us get the program in place in a way that you as regulators would like to see in place.
Please feel free to contact me directly at 919-553-1536 or by email at [e-mail] anytime.
Respectfu Ily,
William Simpson
Town of Clayton, Sam's Branch WRF
Plant Superintendent
[e-mail]
919-553-1536
CC Electronically:
Rich Cappola, Town Manager
Byron Poelman, Water Resources Director
Heidi Holland, Town Clerk
PO Box 879 • Clayton, NC, 27528 • 919-553-5002
LAYTVN
Fax [phone] • TownofClaytonNC.org

NC De
tofPn,;. .
ImircoiNgER11
114 OAKMONT DRIVE
GREENVILLE, N.C. 27858
ncErjArraNd
NC Dept of Environmental Quality
NOVO NORDISK
ATTN: PAUL MORRIS
3612 POWHATAN RD.
CLAYTON, NC 27527
PARAMETERS
PH (field measurement), Units
BOD, mg/l
COD, mg/1
Total Suspended Residue, mg/1
Ammonia Nitrogen as N, mg/1
Total Kjeldahl Nitrogen as N,mg/1
Nitrate+Nitrite as N, mg/1
Total Phosphorus as P, mg/I
Total Cyanide, mg/1
Fluoride, mg/1
Total Dissolved Residue, mg/l
Arsenic, ug/1
Barium, ug/l
Cadmium, ug/1
Copper, ug/1
Total Chromium, ug/I
Lead, ug/1
Mercury, ug/1
Molybdenum, ug/I
Nickel, ug/1
Selenium, ug/I
Silver, ug/I
Zinc, ug/I
Temperature, °C
Total Nitrogen, mg/I (calc)
JAN 1 7 2023
Raleigh Regional Office
Pipe Analysis Method
002 Date Analyst Code
8.3 09/01/22 NNK 45001-I33-11
20 09/02/22 JDJ 5210B-16
108 09/02/22 HMM H8000-79
9.5 09/02/22 BNC 2540D-15
2.92 09/02/22 TRJ 350.1 R2-93
6.88 09/13/22 TRJ 351.2 R2-93
0.90 09/08/22 KES 353.2 R2-93
1.14 09/15/22 BMD 365.4-74
<0.005 09/06/22 HMM 4500CNE-16
0.34 09/02/22 BLV 4500FC-11
1400 09/06/22 BNC D5907-13
<3.0 09/14/22 NAB EPA200.8
55 09/06/22 MTM EPA200.7
1 09/14/22 NAB EPA200.8
61 09/14/22 NAB EPA200.8
<2.0 09/14/22 NAB EPA200.8
<5.0 09/14/22 NAB EPA200.8
<0.2 09/07/22 MTM 245.1 R3-94
<5.0 09/27/22 MTM EPA200.7
5 09/14/22 NAB EPA200.8
<10 09/26/22 MTM 31138-10
2 09/14/22 NAB EPA200.8
65 09/14/22 NAB EPA200.8
10 09/01/22 NNK 25508-10
7.78
Drinking Watir ZDs 37715
Wastewater ID, 10
PHONE [phone]
FAX [phone]
ID#: 191 A
DATE COLLECTED: 09/01/22
DATE REPORTED : 09/28/22
REVIEWED BY:

Environment 1. Inc.
P.O. Box 7085, :14 Oakmont Dr.
CHAIN OF CUSTODY RECORD
Pattc
1
LUC IIVIIIG. Ill. _/n.lu
env i ronmen t l inc.com
Phone [phone] • Fax [phone] +
CLIENT: 191 A Week: 32
dOVONORDISK
►TTN: PAUL MORRIS
612 POWHATAN RD.
:LAYTON NC 27527
919) 550-2200
DISINFECTION
riji
Liu
Ul
(—j
ti.•11
CHLORINE
v
NONE
f t
J
CHLORINE NEUTRALIZED AT COLLECTION
pH CHECK (LAB)
!)
/J
li /r%iV
�f
/J
I/ Ln/i
.-i'
„k
p
p
p
p
p
p
CONTAINER TYPE, PIG
A
A
C
A
C
C
C
C
D
A
A
A
A
A
CHEMICAL PRESERVATION
TOTAL CHLORINE. mg/1
OR ugll AT COLLECTION
TEMPERATURE. °C
AT COLLECTION
# OF CONTAINERS
lad
w
BOD
C
C.
TSR
Ammonia Nitro.
TKN
L
2
w
Z
T. Phosphorus
a)
Pn
U
Fluoride
TDS
T.
3
! .S
d
i
Temperature
Total Nitrogen
PARAMETERS/TESTS
A -NONE D-NAOH
B HND3 E - HCL
C-H?SO4 F - ZINC ACETATEINAOH
G - NATHIOSULFATE
COLLECTION
SAMPLE LOCATION
DATE
TIME
Pipe 002
9 - (- 2 Z
([. � 20r
� 0
10
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....
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r ';�'•'.
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LiWASTEWATER
jDRINKING
LIDWRiGW
Di
CLASSIFICATION:
(NPDES)
WATER
SOLID WASTE SECTION
CHAIN OF CUSTODY (SEAL) MAINTAINED
DURING S ENT/DELIVERY
N
SAMPLES COLLECTED BY:
(Please Ptint) r,/pel;, ,i , EG-CA r n
S3 r,c.k ... (.-IALt•._)
SAMPLES RECEIVED IN LAB AT Z•CP :C
RELINQUISHED B IG.) (SAMPLER)
�
DATE1i1ME
-I-7 �
l,0g1"
RECEIVED BY (SIG.)
>, . - .
U ATE/IIME
// j
2 -. i5
COMMENTS:
RELINQUISHED BY (SIG.)
DATE/TIME
CEIVED BY (SIG.)
DATE/TIME
l
RELINQUISHED BY (SIG.)
DATEITIME
1
RECEIVED BY (SIG.)
DATE/TIME
FORM 05
PLEASE READ Instructions for completing this form on the reverse side.
Sampler must place a "C" for composite sample or a "G" for
Grab sample in the blocks above for each parameter requested.
NQ 410949

EMAIToo.�igo `i k000[
114 OAKMONT DRIVE
GREENVILLE, N.C. 27858
NOVO NORDISK
ATTN: PAUL MORRIS
3612 POWHATAN RD.
CLAYTON, NC 27527
PARAMETERS
PH (field measurement), Units
BOD, mg/I
COD, mg/1
Total Suspended Residue, mg/I
Ammonia Nitrogen as N, mg/I
Total Kjeldahl Nitrogen as N,mg/I
Nitrate+Nitrite as N, mg/I
Total Phosphorus as P, mg/1
Total Cyanide, mg/I
Fluoride, mg/I
Total Dissolved Residue, mg/1
Arsenic, ug/1
Barium, ug/I
Cadmium, ug/I
Copper, ug/l
Total Chromium, ug/1
Lead, ug/I
Mercury, ug/I
Molybdenum, ug/l
Nickel, ug/I
Selenium, ug/l
Silver, ug/I
Zinc, ug/I
Temperature, °C
Total Nitrogen, mg/l (calc)
Po
ratM
Pipe Analysis Method
002 Date Analyst Code
9.7 03/31/22 TJD 4500HB-11
r 22 03/31/22 DNS 5210E-16
133 04/01/22 JMS H8000-79
5.6 04/01/22 HMV 2540D-15
3.06 04/01/22 TRJ 350.1 R2-93
3.93 04/05/22 ICES 351.2 R2-93
0.27 04/01/22 BMD 353.2 R2-93
0.15 04/05/22 KES 365.4-74
<0.005 04/07/22 JMS 4500CNE-16
0.24 04/01/22 CAW 4500FC-11
320 04/05/22 DIJ D5907-13
<2.0 04/07/22 MTM 3113B-10
< 10 04/06/22 LFJ EPA200.7
< 1.0 04/06/22 MTM 3113B-10
113 04/06/22 LFJ EPA200.7
<2.0 04/06/22 LFJ EPA200.7
< 5.0 04/05/22 MTM 3113B-10
<0.2 04/18/22 MTM 245.1 R3-94
< 5.0 04/06/22 LFJ EPA200.7
3 04/06/22 LFJ EPA200.7
< 10 04/18/22 MTM 3113B-10
< 1.0 04/06/22 LFJ EPA200.7
40 04/06/22 LFJ EPA200.7
8 03/31/22 TJD 2550B-10
4.20
A11 QC requirements were not mete r Replicate varied by more than 30%.
Drinking Water ID: 37715
Wastewater IDt 10
PHONE [phone]
FAX [phone]
ID#: 191 A
DATE COLLECTED: 03/31/22
DATE REPORTED : 04/20/22
REVIEWED BY:

'an 1.10
114 OAKMONT DRIVE
GREENVILLE, N.C. 27858
NOVO NORDISK
ATTN: PAUL MORRIS
3612 POWHATAN RD.
CLAYTON, NC 27527
PARAMETERS
PH (field measurement), Units
BOD, mg/I
COD, mg/I
Total Suspended Residue, mg/I
Total Phosphorus as P, ►ng/I
Total Dissolved Residue, mg/I
Temperature, °C
Pipe Analysis Method
002 Date Analyst Code
8.2 06/15/22 NNK 4500HB-11
g 31 06/15/22 JMS 5210B-16
96 06/17/22 HMM I18000-79
15 06/16/22 DIJ 2540D-15
1.56 06/28/22 BMD 365.4-74
320 06/16/22 HMV D5907-13
10 06/15/22 NNK 2550B-10
Drinking Water ID: 37715
Weetewater ID: 10
PHONE [phone]
FAX [phone]
ID#: 191 A
DATE COLLECTED: 06/15/22
DATE REPORTED : 06/29/22
REVIEWED BY:
A11 QC requirements were not met. g GGA check standard was not 198 ± 30.5 mg/1.

Town of Clayton
Public Works
PO Box 879
Clayton, NC 27528
i
USPS CERTIFIED MAIL
i
i
i
i
i
9214 8901 9403 8300 8375 37
II I
CHENG ZHANG
WATER QUALITY REGIONAL OPERATIONS SECTION
RALEIGH REGIONAL OFFICE
DIVISION OF WATER RESOURCES, NCDEQ
MAIL SERVICE CENTER 1628
RALEIGH, NC 27609-1628
NC Dept of Environmental Quality
JAN 1 7 2023
Raleigh Regional Office
Postage: $6.8100