NC0025453_Pretreatment Compliance Inspection_20240708

DocuSign Envelope In 84CD6D64-E66B-46BA-8E02-7D72BCF61C2?
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. Richard Cappola,
Town of Clayton
P.O. Box 879
Clayton, NC 27520
Subject:
Dear Mr. Cappola:
NORTH CAROLINA
Environmental Quality
July 8, 2024
Town Manager
Pretreatment Compliance Inspection
Town of Clayton
NPDES Permit No. NCO025453
Johnston County
On June 26, 2024, 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. David White, the
wastewater operations superintendent, and Mr. James Warren, the Pretreatment Coordinator, was greatly
appreciated. The inspection report is attached. Findings during the inspection were as follows:
There are three Significant Industrial Users (SIUs), which are also Categorical Industrial Users
(CIUs). It was noted that Novo Nordisk API was in Significant Non -Compliance (SNC) during
the two most recent six-month periods.
2. The pretreatment inspection file review included Novo Nordisk IFP (Permit No. 0003-02), Novo
Nordisk API (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
2023, Novo Nordisk IFP and Grifols were compliant. Novo Nordisk API was in SNC for
multiple violations for TDS. Industrial User Pretreatment Permits (IUPs) for all three SIUs were
renewed on May 1, 2024, close to two years past the IUPs expiration date. Please submit Novo
API's IUP to the Division for review and approval.
3. A review of the files containing the pretreatment program elements was conducted. These files
were well organized and up to date. The Town submitted update of Headwork Analysis on May
3, 2024, and update of Industrial Waste Survey on February 5, 2024, well past the required due
dates.
4. The review of Long Term Monitory Plan data indicated that all locations were sampled with
required frequencies since the last inspection.
5. The program has recovered from the setback caused by personnel turnover in the past two years,
submitted updates of HWA and IWS in 2024, and renewed IUPs for all three SIUs in May 2024.
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office I 3800 BarrettDrive I Raleigh, North Carolina 27609
NORTH CAROLINA ^ 919.791.4200
n�,Mo E,Amnm W1 Q­1K,

DocuSign Envelope ID: 84CD6DB4-E66B-4BBA-8E02-7D72BCFB1C22
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:
Vaun t,SSa f.
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)
James Warren, Town of Clayton (electronic copy only)
D � ��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA ��` 919.707.9000

DocuSign Envelope ID: 84CD6DB4-E66B-4BBA-8E02-7D72BCFB1C22
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
WaterResaurces
ENVIRONMENTAL QUALITY
BACKGROUND INFORMATION [Complete Prior To PCI; Review Prollram Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Clayton
2. Control Authority Representative(s): David White, James Warren
3. Title(s): Water Reclamation Superintendent, Pretreatment Coordinator
4. Last Inspection Date: September 9, 2022 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 MM/DD/YY
I NICIO 10 1 21 5 14 1 513 1 1 06 1 261 24 1
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 SNC for
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for
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?
® YES [-]NO
10/23 ammonia, 7/23 DO, 9/22 TP
❑ YES ®NO
Limits: Novo API
Reporting: None
dished: None
None
DYES [-]NO
Grifols' IUP
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 ❑ 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
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:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

DocuSign Envelope ID: 84CD6DB4-E66B-4BBA-8E02-7D72BCFB1C22
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)
5/3/2024
® Yes ❑ No
6/23/2017
® Yes ❑ No
4/1/2022
Industrial Waste Survey (IWS)
2/5/2024
® Yes ❑ No
10/31/2018
® Yes ❑ No
10/01/2023
Sewer Use Ordinance (SUO)
1/4/2013
® Yes ❑ No
1/11/2013
® Yes ❑ No
Enforcement Response Plan (ERP)
1 2/14/2020
® Yes ❑ No
3/17/2020
❑ Yes ® No
Long Term Monitoring Plan (LTMP)
1 4/3/2017
® Yes ❑ No
6/20/2017
® 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 IFP
2. Grifols
3. Novo Nordisk API
30. IUP Number
0003-02
0 001-02 11
0002-05
31. Does File Contain Current Permit?
® Yes
❑ No
® Yes ❑
I ® Yes ❑ No
32. Permit Expiration Date
6/30/2026
6/30/2026
6/30/2026
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
439.40
439.20
439.A
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?
I ® Yes ❑ No
® Yes ❑ 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
b. ❑Yes ❑No
b. ❑Yes ❑No
b. []Yes []No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
Organic Management Plan (TOMP)?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. EYes ❑No
a. ®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
® Yes ❑ No
its Sampling as Required by IUP, including 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
OYesONoEIKI
®Yes❑No❑N/A
®Yes❑No❑N/A
Sampling as Required by IUP, including flow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
®Yes❑No❑N/A
EYcs❑No❑N/A �7csE]NoON/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoEN/A
❑Yes❑N00
❑Yes❑NoEN/A
file include process/dilution flows as Required b IUP?
42b. For categorical IUs with Production based limits, does file include
Yes❑NoEN/A
P
❑Yes❑NoEN/A
❑Ycs❑NoEN/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoEN/A
❑Yes❑NoEN/A
EYes❑No❑N/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
All Re ortin Non-Com liance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑NoEN/A
a.❑Yes❑NoEN/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❑NoEN/A
c.❑Yes❑NoEN/A
c.❑Yes❑NoEN/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
❑
Yes
®
No
®
Yes
❑
No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑NoEN/A
❑Yes❑NoEN/A
EYes❑No❑N/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
50. a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑NoEN/A
a.❑Yes❑NoEN/A
a.❑Yes❑NoEN/A
b. Is SIU in Compliance with Order?
b.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ® No
❑ Yes ®No
❑ Yes ® No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

DocuSign Envelope ID: 84CD6DB4-E66B-4BBA-8E02-7D72BCFB1C22
FILE REVIEW COMMENTS:
21— Grifols IUP is under adjudication.
38 — All three IUPs were renewed on May 1, 2024.
46 — Novo API was in SNC for TDS limit violations during the second semi -annul period of 2023.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
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 has recovered from the setback caused by personnel turnover in the past two years, submitted updates of
HWA and IWS in 2024, and renewed IUPs for all three SIUs in May 2024.
Requirements: Submit Novo API's IUP to the Division for review.
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: June 26, 2024
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3