NC0025453_Pretreatment Compliance Inspection_20160921

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Water Resources
ENVIRONMENTAL QUALITY
September 21, 2016
Mr. Steve Biggs
Town Manager
Town of Clayton
P.O. Box 879
Clayton, NC 27520
Subject: Pretreatment Compliance Inspection
Town of Clayton
NPDES Permit No. NCO025453
Johnston County
Dear Mr. Biggs:
PAT MCCRORY
Crovemor
DONALD R. VAN DER VAART
Serawttuy
S. JAY ZIMMERMAN
Director
RECE{UEDINCDENWR
SEP 27 2016
Water Quality
permitting Section
On September 21, 2016, 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. James
Warren, the wastewater operations superintendent, was greatly appreciated. The inspection report is
attached. Findings during the inspection were as follows:
1. There are 2 Significant Industrial Users (SIUs), which are also Categorical Industrial Users
(CIUs). It was noted that Novo Nordisk was in Significant Non -Compliance (SNC) for reporting
violation during the most recent six-month period.
2. 'The pretreatment inspection file review included Novo Nordisk (Permit No. 0003-02) and
Grifols (Permit No. 0001-02). The files needed for review were available for inspection,
contained all the required elements and were in excellent condition. During the first six-month
period of 2016, Grifols had three total nitrogen and one TSS violations. Novo Nordisk failed to
sample, analyze, and report BOD, COD, and TSS during the second quarter, which resulted in
SNC. These violations were addressed appropriately as required by the Enforcement Response
Plan (ERP). It was noted that the POTW did not sample and analyze pharmaceutical
parameters during this period. Mr. Warren stated that these parameters were sampled in
September, and will be sampled again in December, to make up the missed sampling.
3. A review of the files containing the pretreatment program elements was conducted. These files
were well organized and up to date.
4. The review of LTMP data indicated that all locations were sampled with required frequencies
and detection limits since the last inspection. Monitoring data were very well maintained in
Division of Water Resources, Raleigh Regional Office, Water Quality Operations Section http://deq.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]

spread sheets. It is recommended that several parameters (temperature, pH, residual
chlorine, DO, TDS, chloride, TOC, and nitrate) be removed from the plan, because they
are not used in Headworks Analysis. Detection limit for effluent mercury shall be modified
to reflect the low level mercury monitoring requirement in the current NPDES permit.
The Town of Clayton's 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 (919)
791-4200 (or email: [e-mail]).
Scer ly,
Dannv Smith
Regional Supervisor
Raleigh Regional Office
Enclosure: Town of Clayton PCI Inspection Form
CC: Monti Hassan, DWR - FPERCS Unit
Cheng Zhang - RRO
Central. Files
James Warren, Town of Clayton
N

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NORTH CAROLINA DIVISION OF WATER QUALITY
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION [Complete Prior To PCI• Review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Clayton - Little Creek Water Reclamation Facility
2. Control Authority Representative(s): James Warren
3. Title(s): Wastewater Operations Superintendent
4. Last Inspection Date: 08/03/2012 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
PCS CODING
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type
I N I I N I C 1 0 1 0 12151415 13 I 1051121 14 P I P I .I 1 I
(DTIA) (TYPI)
(INSY)
(rAUL;
7. Current Number Of Significant Industrial Users (SIUs)?
2
SNS
8. Current Number Of Categorical Industrial Users (CIUs)?
2
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 Expired IUP
0
NOCM
13. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2
11
1
PSNC
Semi -Annual Periods Total Number of SIUs in SNC)
14. Number of SILTS in SNC For Reporting During Either of the Last 2 Semi -Annual Periods
1
MSNC
15. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods
0
_7
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? ❑ YES ® NO
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 N YES U NO
Discharge (Interference, Pass -Through, Blockage, Citizens' Complaints, Increased
Sludge Production, Etc.)? Elevated phosphorous level from domestic now. A non -
SIU is the suspected source.
If Yes, How are these Problems Being Addressed? Increase chemical feed rate
19. Which Industries have been in SNC for Limits or Reporting during either of SNC for Limits: None
the Last 2 Semi -Annual Periods? Not Been Published for Public SNC for Reporting: Novo Nordisk
Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published: None
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? None
21. Are Any Permits Or Civil Penalties Currently Under Adjudication? If Yes, Which ❑ YES ®NO
Ones?
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 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? ® YES ❑ NO
If yes, which ones? Eliminated: temperature yH residual chlorine, DO, TDS, chloride, TOC, nitrate Added:
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page I

is
28. PRETREATMENT PROGRAM ELEMENTS REVIEW- Please review POTW files, verify POTW has copy of Program '
Element in their files, complete with sup orting 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 WA)
05/30/2012
® Yes ❑ No
08/21/2012
® Yes ❑ No
04/01/2017
Industrial Waste Survey (IWS)
10/03/2013
® Yes ❑ No
11/21/2013
® Yes ❑' No
10/01/2018
Sewer Use Ordinance SUO
01/14/2013
® Yes ❑ No
01/11/2013
® Yes ❑ No
06/30/2017
Enforcement Response Plan RP
09/09/2008
® Yes ❑ : No
10/10/2008
® Yes ❑ No'!
33. Categorical Standard A ` lied I.E. 40 CFR, Etc. Or N/A
Long Term Monitoring Plan (LTMP)
12/13/2013
® Yes ❑ No
02/21/2014
® Yes No
® Yes. EJNo
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. 2. Novo Nordisk''
3. Grifols
30. IUP Number
0003-02
0001=02
31. Does File Contain Current Permit?
® Yes ❑ No
® Yes No
32. Permit Expiration Date
06/30/2017
06/30/2017
33. Categorical Standard A ` lied I.E. 40 CFR, Etc. Or N/A
439.40
439.20
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes. EJNo
® Yes El
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
® Yes ❑ N_o__Jj
® Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
a. ®Yes E]NO7
a. ®Yes []No
b. If No, is One Needed? (See Inspection Form from POTW)
b. []Yes ❑No
11 b. ❑Yes F11-
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑No®N/A
❑Yes❑No[R
Organic Management Plan (TOMP)?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes ❑No
a. ]Yes []No
b. All Issues Resolved?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
39. During the Most. Recent Semi -Annual Period, Did the POTW Complete
-1[®
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__1j
® Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its❑Yes®No❑N/A
_11
®Yes❑No❑N/A
Sampling as Required by IUP, including flow? IL
11
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
F ®Yes❑No❑N/A .1[resONoDN/A
on time?.
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑No®N/A
file include process/dilution flows as Re ired by IUP?
w
42b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
❑Yes❑NoON/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❑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❑No❑N/A
❑Yes❑No®N/A
All Re ortin Non -Com fiance from SIU Sampling?
44. a. Was the POTW Notified by S1U (Within 24 Hours) of All Self-
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❑NomN/A
b.❑Yes❑NomN/A
c. If applicable, Did POTW resample within 30 days of becoming aware
of SIU limit violations in the POTW's sampling of the SIU?
c.❑Yes❑No®N/A
c.®Yes❑No❑N/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
® Yes El -No
_Yes® No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
®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❑No®N/A 11
❑Yes❑No®N/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NO®N!A
❑Yes❑No®N/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
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ® No
❑ Yes ® No
Requested Information For You?
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

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FILE REVIEW COMMENTS:
#39 — The POTW did not sample pharmaceutical parameters at Grifols during the first half of 2016, makeup sample will be taken
during the second half of 2016.
#41— Novo Nordisk failed to sample and analyze BOD, TSS, and COD for the second quarter of 2016, which resulted in SNC. The
POTW issued a NOV for this reporting violation on July 26, 2016, requesting the SIU to make up the missed -parameters in
the third quarter.
#43a — Grifols had one TSS and three total nitrogen violations, the POTW issued two NOVs to address these violations.
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type
INJ JNIQI0I 0121514 15131 1 1 L-1 J I I J SJ L-2 J
(DTIA) (TYPI) (INSP) (FACC)
1. Industry Inspected:_
2. Industry Address:_
3. Type of Industry/Product:-
4. Industry Contact:_ —Title:—
Phone:
itle:_
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
ElYES ❑ NO
D. Sampling Review
❑ YES ❑ NO
E. Exit Interview
❑ YES ❑ NO
Industrial Inspection Comments:
OVERALL SUMMARY AND COMMENTS:
Comments:
Requirements:
Recommendations:
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ® Marginal ❑ UnSatisfactory_❑
PCI COMPLETED BY: Cheng Zhang DATE: September 21,201
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3