NC0026051_Petreatment Compliance Evaluation Inspection_20200318 (2)

ROY COOPER
Co�cmor
I`VIICHAEL S. REGAN
searran
S. DANIEL SMITH
Virccror
,IDRTH CAROIINA
Environmental Quality
March 18, 2020
Ms. Stephanie Brixey, Deputy Director
Department of Engineering and Environmental Services
Durham County
5926 NC Hwy 55 E
Durham, NC 27713
Subject: Pretreatment Compliance Inspection
Durham County Triangle WWTP
NPDES Permit No. NC00260S1
Durham County
Dear Ms. Brixey:
On March 4, 2020, Cheng Zhang of the Raleigh Regional Office (11110) conducted a
Pretreatment Compliance Inspection of Durham County's pretreatment program. The
assistance given by Ms. Amy Moore, the Compliance Manager, was greatly appreciated. The
inspection report is attached. Findings during the inspection were as follows:
1. There are 13 Significant Industrial Users (SIUs), 12 of which are also Categorical
Industrial Users (CIUs). It was noted that Aurobindo was in significant non-
compliance for the second six-month period of 2019 for acetone violations.
2. The pretreatment inspection file review included Aurobindo (Permit No. DC-089),
AstraZeneca (Permit No. DC-078), and Biogen (Permit No. DC-080). The files
needed for review were available for inspection, contained all the required elements
and were in excellent condition.
3. The POTW and three SIUs completed monitoring as required by the Industrial User
Pretreatment Permits (IUDs) during the second semi-annual period of 2019.
AstraZeneca was in compliance. Biogen had one reporting violation (late in monthly
flow report submission for November 2019). Aurobindo had multiple acetone
violations in August and September, and was in SNC for TRC violations of acetone
monthly average limit.
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4. A review of the files containing the pretreatment program elements was conducted.
These files are well organized and up to date. Enforcement Response Plan was
updated and approved recently.
5. Long Term Monitoring Plan (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.
Durham County'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 [phone] (or email: [e-mail]).
Sincerely,
,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
ATTACHMENTS
PC[ Inspection Reports
Cc: Central Files w/attachment
Raleigh Regional Office w/attachment
Amy Moore (electronic copy only)

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COLNIPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFOILNIATION [Complete Prior To PCI,• Review Pro4iram Info Database Sheetfs
1. Control Authority (POTW) Name: Durham County- Triangle «'NN'TP
2. Control Authority Representative(s): Amy Moore
3. Title(s): Compliance Manager
4. Last Inspection Date: August 16 2018 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 E NO
Order Type, Number, Parameters: Are Milestone Dates Being Nlet? ❑ YES ❑ NO
ICIS CODING
Main Program Permit Number M%1 DD YY
N I C 1 0 1 0 1 21 6 1 0 1 51 1 1 L03 1 04 1 20
7. Current Number OF Significant Industrial Users (SiUs)?
13
8. 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 Period?
1
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
15. Current Number Of Cate orical Industrial Users (CIUs)?
12
16. Number of CIUs in SNC?
1
POTW INTERVIEW
I7. Since the Last PCI, has the POTW had any NPDES Limits Violations'? EYES ❑ NO
If Yes, What are the Parameters and How are these Problems Being Addressed`? BOD, 9/2018
18. Since the Last PCI, has the POTW had any Problems Related to an Industrial ❑ YES ®NO
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 SNC for Limits: Aurobindo for acetone violations
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for Reporting: None
Public Notice?(Nlay 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 None
Order, Has a Signed Copy of the Order been sent to the Dig ision?
21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which ❑ YES ®NO
Ones?
LM%IPISTi IP 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 LTNIP.:STMP Monitoring? ® YES ❑ NO
24. Is LTMPfSTMP 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 verify yourself?
26. If NO to 23 - 26, list violations
27. Should any Pollutants of Concern be Eliminated from or Added to LTNIP; STNIP'? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
NC DWR Pretreatment Compliance inspection (PCI) Form Updated December 2016 P:t e i

28. PRETREATMENT PROGRAM ELEMENTS REVIENV - Please review POTW files, verify POTW has copy of Program Element in
their files. complete with sutmortine documents and cnnv nF PFRC C, Annmv�l I oit, r qnd At.. . ;ti, n—.,...,.,, t.,r .
Program Element
Last Submittal
Date In tile?
Last Approval
Date In rile
Date Next Due,
If Applicable
Headworks Analysis (HWA)
311612018
Yes LJ No
5/2/2018
Yes 0 No
4/1/2023
Industrial Waste Survey IWS)
3/1412016
Yes 0 No
5/31/2016
L<j Yes Ll No
4/1/2021
Sewer Use Ordinance SUO
12120.1012
Yes LJ No
4/3/2013
Yes Lj No
Enforcement Response Plan (ERP)
24 V2020
Yes U No
2/1312020
Yes No
Long Term Monitoring Plan (LT?*IP)
9f9f2413
Yes No
10/8/2013
Z Yes LLJj No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 [UP FILE REVIEWS OR 1 FILE REVIEW AND I [U INSPECTION)
29, User Name
1, Aurobindo
2. AstraZeneca
3. Biogen
30. IUP Number
31. Does File Contain Current Permit?
DC-089
Lj Yes LjNo
DC-078
VA Ye Lj No
DC-080
N Yes 0 No
32. Permit Expiration Date
10/8/2024
12/31/2021
8/23/2020
33. Categorical Standard Ap2lied (I.E. 40 CFR, Etc.) Or N.A
439 D&E
439 D&E
439 D&E
34, Does File Contain Permit Application Completed Within One Fear Prior
Yes El No
®YesEl No
Yes El No
to Permit Issue Date?
35, Does File Contain an Inspection Completed Within Last Calendar Year?
Yes No
S'esLi N-o-J,
Z Yes No
36. a_ Does the File Contain a Slug Spill Control Plan?
b. If No, is One Needed'? (See Inspection Form from POTW)
a. ®Yes ❑No Ia.
b. ❑Yes ❑No 11
®Yes ❑No
b. ❑Yes 0
a. ®Yes ❑No
1 b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
❑YcS❑No®N A
7EIYcs0No0N_Aj
❑Yes❑NoON A
3& a_ Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. ®Yes [IN o
b ❑Ycs❑No❑N A
a. ®Yes ❑No
b ❑YLs❑No❑N All
a. ®Yes ❑No
b ❑Y,s❑tio❑ v A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
Yes ElNo
S'esLj No
17
Yes No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
L9 Yes U No
Yes El No
Yes No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sam lin as Re uired b IUP, includin flow?
®Ye,❑No❑�I A
®Yci❑No❑V A
®Ycs❑No❑V A
41b. During the Most Recent Semi -Annual Period, Did S[U submit all reports
on time?
0Y45❑NOON A
®Yes❑No❑N A
❑Ycs®No❑N A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process2dilution flows as Required b [UP?
❑Yes❑NoON A
❑N'esONo®N A
❑Yes❑NoON A
42b_ For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
0Ycs❑No0N A
❑Ycs❑No®N A
❑Ycs❑No®N A
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sam line?
EWL-�ONo❑N'A
❑N'es❑NoON A
❑Yes❑No®N A
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Re ortin Non-Com liance from SIU Sampling?
❑Yes❑No®N A
❑Yes❑NoON'A
®Yes❑No❑N A
44. a. Was the POTW Notified by SIU (Within 24 hours) of All Self-
Monitoring Violations?
a.®Ycs❑No❑N A
a.❑ cs❑No®N A
a.0Yes0No0N A
b. Did Industry Resample and submit results to POTW Within 30 Days?
b ®Y,,i0Na[3N A
b pees❑NOON A
b ❑Yts❑NoGN 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?
` ❑ti `❑y°mN A
s.❑Y°'❑N°®N A
c ❑Ycs❑tio®ti A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
Yes ❑ No
Yes 0 No
Yes No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timin *, etc.)?
®Ycs❑No❑N A
OYes❑NoON.A
®Ycs❑No❑N-A
48. Does the File Contain Penalty Assessment Notices'?
❑Ycs❑NOO
❑Yes❑NoON!A
❑Ycs❑No®N A
49. Does The Fife Contain Proof Of Penalty Collection'?
❑Ycs0No0N.A
❑Ycs❑NoON1A
❑Ycs❑NOON A
50, a. Does the File Contain Any Current Enforcement Orders'?
b_ Is SIU in Compliance with Order?
a.❑YoboNnEIN A
b OY4MNLION A
a.❑Yes❑NoON A
b ❑Yes❑*0N A
a.❑Yes❑No®N A
b 0Yes0N;o0N A
51. Did the POTW Representative Have Difficulty in Obtaining Any of Thi{
Requested Information For You?
❑ Yes ® No
Yes ® goYes
No
NC DWR Pretreatment Compliance Inspection (PCI) Forth )Updated Drcembcr 2016 Pa-e 2

FILE REVIEW CONI3IENTS:
41b- Biogen was late to submit its monthly flow report in November 2019.
43a — Aurobindo had multiple acetone violations in August and September 2019.
43h — The POTW identified Biogen's report violation.
46 — Aurobindo was in SNC for TRC violations (acetone monthly averages)
47 — The POTR' issued two NOVs to Aurobindo and one NOV to Biogen.
INDUSTRY INSPECTION IC1S CODING:
Main Program Permit Number
I. Industry Inspected:
2. Industry Address:
3. Type of Industry,' Product:
4. Industry Contact_ Title:
NIXI DD YY
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 ❑ YES [:]NO
D. Sampling Review ❑ YES ❑ NO
E_ Exit Interview ❑ YES ❑ NO
Industrial Inspection Continents;
OVERALL SUMMARY AND CO,NINIENTS:
Comments: The Rrogram is well managed.
Requirements: None
Recommendations; None
NOD: ❑ YES ®NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ®NO
POTW Rating:
Satisfactory ®Marginal ❑ UnSatis€actory ❑
PCI COMPLETED BY: Cheng Zhang. Raleigh Regional Office DATE: March 4, 2020
NC DWR Pretreatment Compliance Inspection (PCO Form Updated December 2016 Page 3