NC0025453_Long Term Monitoring Plan_20170403

TOWN, OF CLAYTON
�sEgvicE".
OPERATIONS.; CENTER`ENVIRONMENT ' - . .
AECTRIC' SERVICE • _ _ . PUBLIC WORKS
[phone] (919) 5534530 `
VEHICLE MAINTENANCE WATER RECLAMATION
[phone] [phone]
.,
April 5,•.201.7 :
Mr. Monte Hassan
Pretreatment Unit
NC DEQ, Division of Water Quality
-1.617 Mail. Service Center
Raleigh,'North Carolina 27699-1617
Re Long Term Monitoring Plan
Town of Clayton, NC
NPDES No. NCO025453
Dear Mr. Hassan:
R �gumn
of 2017mspgaaafty
Enclosed please find an updated Long Term Monitoring Plan for the Town of Clayton.
As recommended by DEQ staff Temp., pH and DO were removed from the list of
parameters. In addition, Hospira has moved from Clayton and therefore removed from
the document. Detection levels were changed to reflect the lowest levels provided by our
outside laboratory (Environment 1).
Please contact me at 919-553-1536 if you have any questions.
Sincerely:
?�ames Warren,
Town of Clayton, Wastewater Operations Superintendent
653 Highway 42 West • P.O. Box 879 • Clayton, North Carolina 27520 • [phone] • Fax [phone]

Long Term Monitoring Plan
Town of Clayton, IVC
Little Creek Water Reclamation Facility
Revisions:
June 1997
September 1997
January 2007
December 2013
April 2017
Prepared By:
James Warren
RECEIVEDI{ NO)DWR
APR 1 0 2017
M910'a",
Pawmagsomion

Town of Clayton
Long Term Monitoring Program
Town of Clayton, NC
Little Creek Water Reclamation Facility
NPDES Permit NCO025453
Overview
As required under North Carolina Pretreatment regulations, this document establishes a long-
term monitoring program for the Town of Clayton's LCWRF for the purposes of:
L Compiling a database characterizing the waste streams received at the treatment works
from industrial, institutional, commercial and domestic users;
ii. Gauging the treatment capability of the Town's treatment works;
iii. Performing and maintaining headworks analysis for the treatment facility;
iv. Establishing local limits for the control of pollutants entering the Town's treatment
facility.
The long term monitoring plan is incorporated as part of the existing monitoring program that
includes the NPDES, Land Application, and Reclaim Water Permits.
It should be noted that this document describes frequencies for the long term operation, since
the first year requirements have been met.
Identification of Pollutants of Concern
The pollutants of concern include parameters listed by the US -EPA guidance documents as
being pollutants of general concern; pollutants limited in the Town's NPDES, Land Application,
and Reclaim Water Permits; and those pollutants listed in industrial wastewater discharge
applications having the potential to harm, inhibit or hinder the treatment process, endanger
personnel, and the environment. Pollutants of concern (POC) are listed under the section titled
Parameters. The Town will also sample domestic only sources to determine background
concentrations for use in the headworks analysis.

Significant Industrial Users
The Town of Clayton currently has two (2) Significant Industrial Users (SIU). These SIUs are
pharmaceutical manufacturers and must comply with local limits and EPA categorical
pretreatment standards. As of the effective date of this document, these SIUs include:
• Grifols SIU# 0001-02
• Novo Nordisk SIU# 0003-02
Sampling schedules are described in each SIU permit for pollutants identified as pollutants of
concern. During the permit renewal process a historical review or additional sampling of
pollutants of concern are required. Additional sampling is also required if an industry exceeds
permit limits for listed parameters, or if an SIU pollutant levels rise. If necessary the Town
reserves the right to sample whenever a potential problem may arise with the treatment works,
collection system, or for concerns with human health and safety.
Little Creek Water Reclamation Facility
The initial short term monitoring requirements have been met; as a result the facility is
operating under the long term scenario. Sampling is conducted to meet the conditions of the
existing permits, quarterly for influent and effluent POCs, semiannually for the activated sludge
mixed liquor, and annually for the domestic waste stream.
Sampling Locations
Sampling locations for data collection and compliance for the SIUs are found in said permits.
Sampling points for the treatment facility are listed below and identified on the plant
schematic.
1) SIUs (off site)
2) Influent
3) Effluent
4) Aeration Basin Mixed Liquor
5) Sludge
6) Domestic (in collection system)

Parameters
The parameters in the long-term monitoring program include pollutants that may
reasonably expected to be discharged into the Town's wastewater collection system or
treatment system in concentrations that may inhibit the Town's ability to discharge effluent
or biosolids within permit limits. In addition, consideration is given for worker or public
safety, and nuisance conditions that may be produced from the discharge of the pollutants.
Any pollutants limited in the Town's NPDES, Reclaim, and Land Application Permits are
automatically considered to be pollutants of concern. Flow monitoring will be available as
needed to quantify pollutants of concern. The following list pollutants of concern, detection
limits, sampling methods, and sampling locations.
Summary of Monitoring Schedule
The facility is currently operating under the long term scenario. The following table
illustrates the sampling frequencies:
Location:
Monitoring Frequency
SIUs (1)
Per IUP
LCWRF: Influent (2)
Quarterly + permit requirements
LCWRF: Effluent (3)
Quarterly + permit requirements
Aeration Basin (4)
Semi -Annually
Biosolids (5)
Annually
Domestic Wastewater (6)
Annually

Pollutants of Concern:
Pharm. 439 includes: Acetone, n -Amyl Acetate, Ethyl Acetate, Isopropyl Acetate, and
Methylene Chloride
Mercury Effluent, EPA 1631
Sample Locations
Pollutant
Det. Limit
mg/I
Sample
Type
SIU
(1)
Inf.
(2)
Eff.
(3)
Aeration
(4)
Sludge
(5)
Domestic
(6)
Metals
Arsenic
0.003
Comp.
X X
X
X
X
X
Cadmium
0.002
Comp.
X X
X
X
X
X
Chromium
0.002
Comp.
X X
X
X
X
X
Copper
0.002
Comp.
X X
X
X
X
X
Cyanide
0.01
Grab
X X
X
X
Lead
0.01
Comp.
X X
X
X
X
X
Mercury
.0002
Comp.
X X
X
X
X
Mercury*
1 ng/I
Comp.
X
Molybdenum
0.005
Comp.
X X
X
X
X
X
Nickel
0.005
Comp.
X X
X
X
X
X
Selenium
0.01
Comp.
X X
X
X
X
X
Silver
0.001
Comp.
X X
X
X
X
X
Zinc
0.01
Comp.
X X
X
X
X
X
Conventional
Flow
n/a
Meter
X
X
X
BOD
2
Comp.
X X
X
X
COD
20
Comp.
X X
X
TSS
2.5
Comp.
X X
X
X
X
Ammonia -N
0.5
Comp.
X X
X
X
X
X
NO2/NO3
0.1
Comp.
X X
X
X
TKN
0.1
Comp.
X X
X
X
T -Nit.
Calculated
Comp.
X X
X
X
T -Phos.
0.1
Comp.
X X
X
X
X
Pharm.439
0.005
Grab
X
Pharm. 439 includes: Acetone, n -Amyl Acetate, Ethyl Acetate, Isopropyl Acetate, and
Methylene Chloride
Mercury Effluent, EPA 1631