NC0025453_CEI Response_20190809

TOWN OF CLAYTON
"SERVICE" OPERATIONS CENTER "ENVIRONMENT'
ELECTRIC SERVICE • PUBLIC WORKS
[phone] [phone]
VEHICLE MAINTENANCE WATER RECLAMATION
[phone] [phone]
entrl i
August 9, 2019 pt of EnvironmeQuality
Rick Bolich, L. G.
Assistant Supervisor, DWR
Raleigh Regional Office
3800 Barrett Dr.
Raleigh, NC 27609
AUG 12 2019
Raleigh Regional off.ce
Re: Pretreatment Compliance Inspection Letter NPDES NC0025453, Dated July 10, 2019, Reply
Mr. Bolich;
The Town of Clayton offers the following replies to items 2 & 4 from the compliance letter dated July 10,
2019.
Item 2 addresses late reports from Grifols Permit # 0001-02. Further investigation into this matter
revealed that the permit contained conflicting information for reporting deadlines in Part I Specific
Conditions G. 6 and Part II General Conditions 2. Part 1 has the last day of the following month and Part
II has the twentieth of the following month. The Town will correct this typo by amending the permit to
reflect the requirement in Part I G. that establishes the reporting date as the last day of the following
month. The amended permit page will be submitted within 10 working days to the PERCs unit. The
Town does not deem it appropriate at this time to take enforcement action on Grifols for the reports
received after the twentieth of the month since IDMRs were received prior to the last day of the month.
If the division does not concur with the Town's determination please let us know.(Pages attached)
Item 4 addresses detection limits for silver, chromium, molybdenum and arsenic. Town staff contacted
the contract lab to have the correct detection limits reported and we have received the corrected
reports. The Town will have all the pertinent reports amended to reflect the values provided by August
30, 2019.
The Town appreciates the consideration of NC DWR in this matter, please contact me at 919-553-1536 if
you have questions or concerns.
Sincerely '
v
mes Warren
Town of Clayton, NC
Wastewater Operations Superintendent
653 Hi6hwuy 42 West - P.O. Box 879 - Clayton, North Carolina 27520 - [phone] - Fax [phone]

Industrial User Pretreatment Permit (IUP)
PART I
Specific Conditions
G.) Definitions and Limit Page(s) notes: (continued)
6. Monitoring and Reporting
All Monitoring shall be performed by a state certified laboratory by
standard methods. Ali data shall be reported to the Division as specified
in Part I1. 2) of this permit, note that violations shall be reported within 24
hours, and that all sampling (even if done more frequently than required)
shall be summarized on turns approved by the Division and sent to the
following address by the last day of the following month:
James Warren, Water Reclamation Superintendent
Town of Clayton
Post Office Box 879
Clayton, North Carolina 27520
7. Notice to Permittees
Permittee is subject to the thirty (30) general conditions attached, found in
Part It of this pen -nit.
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Industrial User Pretreatment Permit (IUP
PART II
General Conditions
Outline of PART II,
1.
Representative Sampling
16.
Federal and/or State Laws
2.
Reporting
17.
Penalties
3.
Test Procedures
18.
Need to Halt or Reduce
4.
Additional Monitoring by
19.
TransferabiIity
Permittee
5.
Duty to comply
20.
Property Rights
6.
Duty to Mitigate
21.
Severability
7.
Facilities Operation, Bypass
22.
Modification, Revocation,
Termination
8.
Removed substances
23.
Reapplication
9.
Upset Conditions
24.
Dilution Prohibition
10.
Right of Entry
25.
Reports of Changed Conditions
11.
Availability of Records
26.
Construction of pretreatment
facilities
12.
Duty to provide information
27.
Reopener
13.
Signatory Requirements
28.
Categorical Reopener
14.
Toxic Pollutants
29.
General Prohibitive Standards
15.
Civil and Criminal Liability
30.
Reports of Potential Problems
Representative Sampling
Samples and measurements taken as required herein shall be representative of the volumc and
nature of the monitored discharge. All samples shall be taken at the monitoring points specified in
this permit and, unless otherwise specified, before the effluent joins or is diluted by any other
wastesircam, body of water, or substance. Monitoring points shall not be changed without
notification to, and approval by, the permit issuing authority.
2. Reporting
a.) Monitoring results obtained by the permittee shall be reported on forms specified by the
Control Authority and/or Municipality, postmarked no later than the twentieth day of the
month follou7ng the month in which the tramples were taken. if nn'dtse arge occurs
during a reporting perio (herein defined as each calendar month) in which a sampling
event was to have occurred, a f'omi with the phrase "no diuiiarge" shall be submitted.
Copies of these and all other reports required hercin shall be submaled to the Control
Authority and/or Municipality and shall be sent to the following address:
James Warren
Water Reclamation Superintendent
Town of Clayton
PO Box 879
Clayton, NC 27520
b.) If the sampling performed by the permittee indicates a violation, the pennittee shall notify the
Control Authority and/or Municipality within 24 hours of becoming aware of the violation.
The permittee shall also repeat the sampling and analysis and submit the results or the repeat
analysis to the Control Authority and/or Municipality within 30 days after becoming aware of
the violation.
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