NC0025453_Pretreatment Compliance_20190710

ROY COOPER
GOVO MIr
MICHAEL S. REGAN
Scrrehlry
LIN€3A CULPEPPER
Ms. Nancy Medlin
Deputy Town Manager
Town of Clayton
P.O. Box 879
Clayton, NC 27520
i FORTH CAROLN "'
Environmental Quality
July 10, 2019
Subject: Pretreatment Compliance Inspection
Town of Clayton
NPDES Pen -nit No. NCO025453
Johnston County
Dear Ms. Medlin:
On June G, 2019, Cheng Zhang of the Raleigh Regional Office conducted a Pretreatment
Compliance Inspection (PCI) of the program at Town of Clayton. Tile 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:
I. There are 2 Significant Industrial Users (SIUs). which are also Categorical Industrial
Users (CIUs). It was noted that neither SIU was in Significant Non -Compliance (SNC)
during the two most recent six-month periods.
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, contained all
required elements. During the second six-month period of 2018, Grifols was late in
submitting monthly flow reports in July, August, September, and August, please
take enforcement action to address these reporting violations. Novo Nordisk was in
compliance.
3. A review of the files containing the pretresitment program elements was conducted.
These files were well organized and up to date. The approval letter from the Division for

the Town's Enforcement Response Plan could not be located. A copy of the letter was
provided to Mr. Warren via email on July 10, 2019.
4. The review of Long Tenn Monitory Plan data indicated that all locations were sampled
with required frequencies since the last inspection. It was noted that the contract
laboratory used higher detection limits for silver, chromium, molybdenum, and
arsenic than those specified in the LTNIP. Please communicate with the lab to
ensure correct detection limits are used in the reports.
Please respond in writing to RRO within 30 days of receipt of this letter regarding Items 2
and 4. Thank you for your continued support of the Pretreatment Program. Ifyou have any
questions or comments, please call Chong Zhang at [phone] (or email:
cheng.zhang(tincdenr.gov).
Sincerely,
10��
Rick Bolich. L.G.
Assistant Supervisor
Division of Water Resources
Raleigh Regional Office
Enclosure: Town of Clayton PCI Inspection Form
CC: Monti Hassan, DWQ - FPERCS Unit
Chong Zhang - RRO
Central Files
James Warren, Town of Clayton (electronic copy only)

NORTH CAROLINA DIVISION OF WATER RESOURCES
' PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet s
1. Control Authority (POTW) Name: Town of Clacton
2. Control Authority Representative(s):.James Warren
3. Title(s): Water Reclamation Superintendent
4. Last Inspection Date: July 28. 2017 Inspection Type (Check One): ❑ PCI ® Audit
5. Has Program Completed Ali 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:
ICIS CODING
Main Pro -min Permit Number
N I C 1 0 1 p 1 21 5 1 4 1 51 3
Are Milestone Dates Being filet? ❑ YES [--],NO
.\1.%1 DD YY
06I061191
7. Current Number Of Significant Industrial Users (SIUs)?
1 2
S. 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
I5. Current Number O£Categorical Industrial Users (CIUs)?
2
16. Number ofClUs 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 I Iow are these Problem,; 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 StiC Ibr
either of the Last 2 Semi -Annual Periods'? Not Been Published for S�tiC tier
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not PuE
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 Pennits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
LTMPISTi•IP FILE REVIEW:
® 1'ES ❑ NO
BOD, April 2019 (4 13 19. weekly
average 11.2 in-L 7.5 mg L limit)
❑ YES ® NO
Limits: None
Reporting: None
�lislted: None
None
❑ YES ® NO
22. Is LTivIP-STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
23. Are Correct Detection Levels being used for all LIMP/SI-MP 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 Division Inspector, please verifyyourselP
26. If NO to 23 - 26, list violations
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP STNIP'? ❑YES ® NO
If yes, which ones? Eliminated: Added:
NC DWR Prelreatmonl f ornnhonrr tncnominn rrrn r.,,,,,, 1 t..,l•,r,..l n.....,,1....• Inlr, n•..... i

28. PRETREATMENT PROGRA�I ELEi1IEN'rS REVIEW- Please review PO I % files, verify POTW has copy of Program Element in
their files, complete with supporting documents and cony of PERCS Approval I ever. and mate.,, rnnsistenr with Prewrs,m info -
Program Element
Last Submittal
Date In rile?
Last Approval
Date In file
Date Next Due,
If Applicable
Ileadivorks Analysis (IIWA)
4/3/2017
Yes El No
612312017
Yes No
4/1/2022
Industrial Waste Surve (IWS)
9/26/2018
El Yes Ej No
10.31/21)18
EFYe, No
10/01/2023
Sewer Use Ordinance (SUO)
1/4/2013
❑C Yes No
I111/2013
® Yes Ll No
Enforcement Response Plan (ERP)
9/9/2008
Yes No
10110/2008
Yes 9 No
Long Term Monitoring Plan (LTMP)
4/3/2017
Yes No
6121112017
L]C Yes Lj No
INDUSTRIAL USER PERMIT (IUP) FILE REV1ENN' (3 IUP FILE REVIEWS OR I FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. Novo Nordisk IF
?. Grifols
3,
30. [UP Number
0003-02
0001-02
31, Does File Contain Current Permit?
ED Yes 0 No
N Yes U Nt�
32. Permit Expiration Date
613012022
6/311/2022
33. Categorical Standard Applied (I.E. 40 CFR. Etc,) Or N A
439.41)
439.20
34. Does File Contain Permit Application Completed X\'ithin One Year Prior
El Yes 0 91��
® Yes ❑ N,-}
to Permit Issue Date'!
35. Does File Contain an inspection Completed Within Last Calendar Year!
ED Yes 0 No
® Yes No
36. a. Does the File Contain a Slug Spill Control Plan'!
a. ®Yes DNo
a. 01'ew ❑No
b. If No, is One Needed'? (See Inspection Form from 110TW)
b. ❑Yes []No
b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑YesC3ti'o®ti
OYcs❑ti"ON
Organic Management Plan (TONIP)?
3't. a. Does File Contain Original Permit Review I -otter from the Division?
a. ®Yes ❑No
a- ®1'es ❑No
b. All Issues Resolved?
b ❑Y%;Nm. >ON A
b ❑Yrs❑Nei❑N A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
El Yes 0No
1'esEj No
its Sampling as Required by IUP, including flow?
40, Does File Contain POTW Sampling Chain -Of -Custody Form,?
X Yeti El No
Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
®l'cs❑No❑N A
A
Sampling as Required by IUP, including flow'?
17csONoON
41b, During the Most Recent Semi -Annual Period, Did SIU submit Al reports
®Ycs❑tie,❑
o❑N A
on time'?
42a. For categorical IUs with Combined Wastestream Formula (C11'F ). does
❑Ycs0tie0N ;\
o(]N A
file include process,dilution flows as Required b • IUP?
42b. For categorical IUs with Production based limits, does file include
❑1'cs❑NoEIN r1
❑YCSONOON A
production rates and. or flows as Required b IUP:'
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑ti'cs❑Nof]N A
OYcso\oEIN A
All Limits Non-Com fiance from Both POTW and SIU Sampling?
-lab. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NtGN-A
❑Ycs❑%00\' A
All Rc ortin Non-Com fiance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self
1-❑YL.<3NiQN A
a.❑Yea❑NoEIN A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
h ❑Yes❑NrmN A
h ❑Yea❑No®N A
c, If applicable, Did POTW resample within 30 days of'becoming aware
g
of SIU limit violations in the POTW's sam lin of the SIU?
O� c,❑NopN
❑Ycs❑Nop A
46. During the Most Recent Semi -Annual Period. Was the SIU in SNC'!
0 Yeti No
El Yes No
47. During the Iviost Recent Semi -Annual Period, Was Enforcement -I aken
❑Ycs❑NoEI ;1
❑Yes❑`oON A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
48, Does the File Contain Penalty Assessment Notices'?
0Ycs0No0N,A 11
❑Ye,❑No®'A
49, Does The File Contain Proof Of PenaltX Collection?
❑Ycs❑No®N'A
❑Yeti❑No®ti A
50. a. Does the File Contain Any Current Enforcement Orders'?
a.0Ycs0N410N A
a.❑Yes❑Nn�]V A
b. Is SIU in Compliance with Order?
b ❑Y�❑No©N .�
b ❑vcs❑No®N A
51. Did the POTW Representative Have Difficulty in Obtaining Any ol'This
❑ Yeti ®
ED No
Requested Information For You?
!1=,,;
NC D%VR Pretreatment Compliance Inspection (PCI) I`onn Updated December2016 11uuc 2

FILL: REVIEW COMMENTS:
41b — Grifols was late in submitting monthly nov.- reports in July, August, September, and October 2018.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number ti1M QD 1'Y
I. Industry Inspected:
2. Industry Address:
3, Type of Industry Product:
d, Industry Contact: Title: Phone: Fax:
5. Does the POTW Use the Division Model Inspection Forth or L;quivalent? ❑ YES ❑ NO
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly"
Comments'.
A. Initial Interview ❑ YES ❑ NO
13- Plant Tour ❑ YES ❑ NO
C. Pretreatment Tour ❑ YES ❑ NO
D. Sampling Review ❑ YES ❑ NO
E. Exit Interview ❑ YES ❑ NO
Industrial Inspection Comments:
OVERALL SU�INIARY AND COMMENTS:
Comments: The program is well managed.
Requirements: Instruct contract lab to use detection limits specified in LTNI P for silver. chromium molybdenum and arsenic. Take
enforcement action a ainst Grifols' reporting Violations in 2018 ver ERP.
Recommendations: None
NOD: ❑ YES ®NO
NOV: D YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
❑ Satisfactory ® Marginal ❑ UnSatisfactory
PCI COMPLETED BY: Chem=_ 7,hang. Raleigh ReLJORal Office DATE:.June 6, 2019
NC DWR Prelrentmvnt f mmnli,mce Insnection (Poi rcinn undated December 2016 Pace 3