NC0025453_Pretreatment Compliance Audit_20171018

Water Resources
CNYMONMENTAL OVAOTY
October 18, 2017
Mr. James Warren
Water Reclamation Superintendent
Town of Clayton
PO Box 879
Clayton, NC 27528
Subject: Pretreatment Compliance Audit
Town of Clayton
Little Creek WWTP - NPDES Permit No NCO025453
Johnston County
Dear Mr Warren -
ROY COOPER
C<_ATyMr
MICHAEL S, REGAN
$,�Crefory
S. JAY ZIMMERMAN
Director
On September 21, 2017, Monti Hassan of the Pretreatment, Emergency Response, and Collection
Systems (PERCS) Unit and Cheng Zhang of the Raleigh Regional Office (RRO) conducted a
Pretreatment Compliance Audit of Johnston County's pretreatment program Your assistance during the
audit was greatly appreciated. The audit report is attached. Findings during the inspection were as
follows:
1. Town of Clayton has two Significant Industrial Users (SIUs), both are also Categorical Industrial
Users (CIUs) It was noted that neither SIU was in SNC for the two most recent semi-annual
penods
2. The pretreatment inspection file review included Gnfols (Permit No 0001-02) and Novo
Nordisk (Permit No. 0003-02) The files needed for review were available for inspection,
contained all the required elements and were in excellent condition.
3 The POTW and SlUs completed monitoring as required by the IUPs during the first semi-annual
period of 2017. Both SlUs were in compliance.
4. A review of the files containing the pretreatment program elements was conducted. These files
were well organized. All elements were up to date. Headworks Analysis was updated and
approved recently
5 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. The data were very well organized in spreadsheets
6. As part of the audit, Mr Warren inspected one of the two SlUs, Gnfols The inspection was very
thorough and covered all required areas.
Division of Water Resouices, Raleigh Regional Office, Nater Quality Operations Section http //deq ne gov/about/divisions/v,atei-resources
1623 Mail Service Center, Raleigh, NC 27699-1623 Phone [phone]
Location 3800 Barrett Drive, Raleigh, NC 27609 Fax [phone]

v
Town of Clayton's pretreatment Program is very well managed Thank you for your continued support
of the Pretreatment Program If you have any questions or comments, please call Cheng Zhang at (91S
791-4200 (or email: [e-mail])
Sinceely,
Danny S;1th
Regional Supervisor
Raleigh Regional Office
Enclosure 2017 Town of Clayton PT Audit Form
CC Monti Hassan, DWQ - PERCS Unit
Central Files
Cheng Zhang, RRO
\j

4
AO
r_0 NORTH CAROLINA DIVISION OF WAT`ER'RESO'URCES
PRETREATMENT AUDIT REPORT
Background Information [Complete prior to audit, reN►ew Program Info Database Sheet(s)]
I Control Authority (POTW) Name Town of Clacton. Little Creek Water Reclamation 1!acilits
2 Control Authority RepresentatiNe(s) James NN arren
3 Title(s) Wastewater Operations Supervisor
4 Addres, of POTW
Nlailma 1000 Durham St. Ext, P O.Box 879
City Carton, NC "Lip Code 27528
,Phone Number [phone] Fax Number [phone] 17 -Mail iowarren n tortinofclatitonnc.or,-
5 Audit Date 9 21 2017
6 Last Inspection Date 9 21 2016 Inspection Type- ®,PCI ❑ Audit
7 Has Program Completed All Requirements from the Previou,, Inspection and Program Int ,Sheet(,) 9 ® Yes ❑ No
If No, Lxplain
8 In the last year has the POTW experienced any NPDLS or Sludge Permit compliance problennO ® Yes ❑ No
If Yes, Explain BOD weekly axerage and monthly average exceeded in April 2017 (caused by hear rain exent)
Did not meet DO daily minimum for 3 times in May 2017
9 Is POTW under an Order That Includes Pretreatment Condition, ❑ Yes ❑ No
Order Type and Number Are Ivtile,'tone Date, Being ,1y1Et) ❑ Ye, ❑ No ❑ NA
Parameters Co%ered Under Order
ICIS Coding
Ma n Program Permit Number
�NIC1010 2 15 14 15 131
MM DD Yl
09 21 17
10 Current Number of Significant Industrial Useis (SIUs)',
11 Number of SIUs ��ith No IUP, or" an Expiied IUP
12 Number of SIUs Not Inspected by POTW in Last Calendai Ycar'a
13 Number of SIU,, Not Sampled by PO -FW in Last Calendar Year)
14 Number of SIUS in SNC for Limits Violations Minn.- Cithea of `L a t ' S mi Annual Periods'
15 Number of SIUs in SNC for Reporting ,During Either f I ast 2 Scmi An11ua1 Periods')
16 Number of SIUs in SNC with Pretreatment Sch dole"
17 Number of SIU, on Schedules''
18 Current Number of Categorical Industrial Users (CIUs)"
19 Number of CIUs in SNC'
2
0
0
0
0
0
0
0
2
0

V
20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element 1
m their Fila nmmnlata with all annnnrtma rincnmentc nnrl PFRC'S Annrnval Tetter_ 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
® Yes ❑ No
6/23/2017
® Yes ❑ No
4/1/2022
Industrial Waste Survey (IWS)
10/3/2013
® Yes ❑ No
11/21/2013
® Yes ❑ No
10/1/2018
Sewer Use Ordinance (SUO)
1/4/2013 ® Yes ❑ No
1/11/2013
® Yes ❑ No
Enforcement Response Plan (ERP)
9/9/2008
® Yes ❑ No
10/10/2008
® Yes ❑ No
Long Term Monitoring Plan (LIMP)
4/3/2017
® Yes ❑ No
6/20/2017
® 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 jurisdiction9
® Yes ❑ No If yes, Please list these towns and/or areas I-401NC 42 area, sending wastewater to Johnston County. Starting
in 2018, sending wastewater to City of Raleigh at 1.25 MGD for the next ten years.
22 If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts9 ® Yes ❑ No ❑ NA
A copy, if not already submitted, should be sent to Division
23 If yes to #21, Have you had any trouble working witl_ 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 SU09 ❑ Yes ® No
If yes, Explain
Enforcement (Enforcement Response Plan -ERP)
26 Did you send a copy of the ERP to your industries9 ® 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, etc9
❑ 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 Following S=Satisfactory M=Marginal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
®S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
®S ❑M ❑U
Emergencies
Access to Operable Sampling
Equipment
®S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
®S ❑M ❑U
Reference Materials
®S ❑M ❑U
Staff Training (i e Annual and
Regional Workshops, Etc )
®S ❑M ❑U
Computer Equipment (Hardware and
Software)
®S ❑M ❑U

30 Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No Excel spreadsheet.
31 How does the POTW recover the cost of the Pretreatment Program from their industries? Explain
Sampling fees.
Public Perception/ Participation
32 Are there any local issues affecting the pretreatment program (e g odor, plant closing, new or proposed plants)9
❑ Yes ® No If yes, Explain
33 Has anyone from the public ever requested to review pretreatment program files9 ® 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 nohow would the request be addressed9 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 pretreatment9 ® Yes ❑ No
36 Is the public notified about changes in the SUO or Local Limits9 ® Yes ❑ No
37 Were all industries in SNC published in the last notice9 ® Yes ❑ No
Permitting (Industrial Waste Survey -I VS)
38 How does the POTW become aware of new or changed Users9 Whenever anew sewer account is established, the user
needs to fill out industrial short 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
SIU9) 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) Sample out truck discharge.
43 How does the POTW allocate its loading to mdustries9 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 allocations9 ❑ Yes ® No
If yes, what parameters are over allocated9
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 / safety9 ® 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 Had difficulty with industries asking for more total nitrogen.
48 How does the POTW decide on which pollutants to limit in the permits? Monitor f6r9 (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.

49 How does the POTW decide what the monitoring fregLency should be for the various pollutants in industry permits9 Explain
Based upon potential to exceed permit limits.
Permit Compliance
50 Does the POTW currently have or during the past year had any permits under adjudication9 ❑ Yes ® No
If yes, which mdustries9 What was (will be) the outcome of the adjudication9
51 Demonstrate how the POTW fudges compliance This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC 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 data9 ❑ 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 adequate9
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 ❑ 1\ o 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 Enrofin
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 Frequencies9 ® 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 (DMM)? ® 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) 9 ® Yes ❑ No
If no, who completes your HWA? Phone () --
62 Do you have plans to revise your HWA in the neer future9 ❑ 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 HWA9 ®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 Find more farmland for land application.

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 N INSPECTION)
66 User Name
1 Novo Nordisk IF 2 Grifols
3
67 IUP Number 1
0003-02
0001-02
68 Does File Contain Current Permits I
® Yes ❑ NoI
® Yes ❑ No
❑ Yes ❑ No
69 Permit Expiration Date 1
6/30/2022 11
6/30/2022
70 Categorical Standard Applied (I E 40 CFR, Etc) Or N/A 1
439.40
439.20
71 Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No®Yes
[:1No
❑Yes ❑ No
to Permit Issue Date
72 Does File Contam Inspection Completed Within Last Calendar Years
I ® Yes ❑ N=ol
® Yes ❑ No 11
❑ Yes ❑ No
73 a Does File Contain Slug/Spill Control Plan?
a NYes ❑No
a NYes ❑No
a ❑Yes ❑No
b If No, is One Needed9 (See Inspection Form from F OTW)
b ❑Yes ❑No
b ❑Yes ❑No
b ❑Yes ❑No
74 For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NoEN/A
❑Yes❑NoNN/A
❑Yes❑No❑N/A
Organic Management Plan (TOMP)9
75 a Does File Contain Original Permit Review Letter from Division9
a NYes ❑No
a ®Yes ❑No
a ❑Yes ❑No
b All Issues Resolved
b ❑Yes❑No❑N/A
b ❑Yes❑No[:1N/A
b ❑Yes❑No❑N/A
76 During Most Recent Semi -Annual Period, Did POTW Complete its
® Yes ❑ No
® Yes ❑ No❑
Yes E]No
Sampling as Required by IUP, including Flow
77 Does File Contain POTW Sampling Chain -Of -Custody Forms9
® Yes ❑ No
®Yes ElNo
❑ Yes ❑ No
78 During Most Recent Semi -Annual Period, Did SIU Complete its
®Yes❑No❑N/A
®Yes❑No❑N/A
11
❑Yes❑No❑N/A
Sampling as Required by IUP, including Flow
79 During Most Recent Semi -Annual Period, Did SIU s_ibmit all reports on
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes❑No❑N/A
time
80a For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoNN/A
®Yes❑No❑N/A
❑Yes❑No❑N/A
file include process/dilution flows as Required by IUPC
80b For categorical IUs with Production based limits, does file include
❑Yes❑NoNN/A
❑Yes❑NoEN/A
Yes❑N
❑o❑N/A
production rates and/or flows as Required by IUPC
81 During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑NOEN/A
❑Yes❑NOEN/A
❑ Yes ❑ No
Limits Non -Compliance from Both POTW and SIU Sampling?
82 During Most Recent Semi -Annual Period, Did POTW Identify All
❑YeS❑NOEN/A
❑YeS❑NOEN/A
❑Yes❑No❑N/A
Reportmg Non -Compliance from SIU Sampling9
83 a Was POTW Notified by SIU (Within 24 Hours) o. All Self-
a ❑Yes❑NoEN/A
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❑No®N/A
b ❑Yes❑No®N/A
b ❑Yes❑No❑N/A
c If applicable, did POTW resample and obtain results within 30 days of
c ❑Yes❑No®N/A
c ❑Yes❑No®N/A
c ❑Yes❑No❑N/A
becoming aware of SIU limit violations in the POTW's sampling of SIU
84 During Most Recent Semi -Annual Period, Was SIU in SNC9
[:1 es ® No
❑ Yes ® No
F ❑ Yes ❑ No
85 During Most Recent Semi -Annual Period, Was Enforcement Taken as
❑Yes❑NONN/A
❑Yes❑NoEN/A
❑Yes❑No❑N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc )9
86 Does File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
11 ❑Yes❑NoEN/A
❑Yes❑No❑N/A
87 Does File Contain Proof Of Penalty Collection9
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑No❑N/A
88 a Does File Contain Any Current Enforcement Orders?
a ❑Yes❑No®N/A
a ❑Yes❑No®N/A
a ❑Yes❑No❑N/A
b Is SIU in Compliance with Order?
b ❑Yes❑No®N/A
b ❑Yes❑No®N/A
b ❑Yes❑No❑N/A
89 Did POTW Representative Have Difficulty in Obtaining Any Requested
❑ Yes ®
® No❑
Yes E]No
Information For Your
!][07Yes
FILE REVIEW COMMENTS:
78 — Grifols is only required to momtor flow, POTW performs monitoring on other parameters

4
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
IN IC 101 01 2 15 14 15 131 1 09 121 1 17 1
1 Industry Inspected Grifols
2 IndustryAddress 8368 US 70 Sus. Hwy W, Clayton, NC 27520
3 Type of Industry/Product Pharmatheutical/Immune globulins
4 IndustryContact Robert Souza Title Engineering Manager Phone [phone] Fax [phone]
5 Does the POTW Use the Division Model Inspection Form or Equivalent9 ®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 SUNLMARY AND COMMENTS:
Audit Comments The program is well managed.
Requirements None
Recommendations' None
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Monti Hassan PERCS Unit Cheng Zhang, Raleigh Regional Office DATE: September 21, 2017