NC0047597_Pretreatment Audit_20201029

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
October 29, 2020
Ms. Vicki Westbrook
Assistant Director of Water Management
City of Durham
101 City Hall Plaza
Durham, NC 27701
Subject: Pretreatment Audit
City of Durham
South Durham WRF - NPDES Permit No. NCO047597
North Durham WRF - NPDES Permit No. NCO023841
Durham County
Dear Ms. Westbrook:
On September 30, 2020, Cheng Zhang of the Raleigh Regional Office (RRO) conducted an audit of
City of Durham's pretreatment program. The assistance given by Mr. Tyrone Battle, the industrial
pretreatment coordinator, was greatly appreciated. The audit report is attached. Findings during
the inspection were as follows:
1. The city has 13 Significant Industrial Users (SIUs), 4 of which are also Categorical Industrial
Users (CIUs). It was noted that there were no SIUs in SNC for the most recent two semi-
annual periods.
2. The pretreatment inspection file review included Cormetech (Permit No. 1036), Corning
(Permit No. 1030) and AW NC (Permit No. 1011). The files needed for review were
available for inspection, contained all the required elements and were in excellent
condition.
3. The POTW and the three SIUs reviewed completed monitoring as required by the Industrial
User Pretreatment Permits (IUPs) during the first semi-annual period of 2020. Cormetech
and Corning were in compliance. AW NC had 6 zinc violations. The City issued two
Notice of Violations for these violations as required by the Enforcement Response
Plan (ERP). AW NC was entered into a consent order for zinc on February 20, 2 02 0.
The order was set to expire on August 31, 2020, but was extended to February 28,
2020. AW NC had been in compliance with the order.
norDE Q�� North Carolina Department of Environmental Quality I Division of Water Resources
r rnani wa Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
oep,m ,t ie n��m.nni"i;� 919.791.4200

4. A review of the files containing the pretreatment program elements was conducted. These
files are well organized. All elements are up to date. ERP was updated and approved
recently.
S. 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.
6. During the audit, Mr. Battle inspected one of the SIUs, Cormetech. The inspection was very
thorough. It was evident that Mr. Battle has good relationship with the industry
representatives and broad knowledge of the SIU's pretreatment operation.
7. It is recommended that the City takes pump station capacities into consideration
when allocating flow to SIUs in the future.
City of Durham'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,
EDocuSigned by:
UaAA1,SSA, f, t't.au WALL
B2916E B 2144F...
Vanessa . anuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Enclosure: City of Durham Pretreatment Audit Form
CC: Central Files w/attachment (Laserfiche)
Cheng Zhang, RRO
Tyrone Battle, City of Durham (Electronic copy only)

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Waterkesources
ENVIRONMENTAL QUALITY
Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Durham City
2. Control Authority Representative(s): Tyrone Battle
3. Title(s): Pretreatment Coordinator
4. Address of POTW:
Mailing 101 City Hall Plaza
City Durham
Phone Number 919-560-4386 Fax Number 919-560-4418
Zip Code 27701
E-Mail Gerald.Battleaa-,durhamnc.2ov
5. Audit Date 09/30/2020
6. Last Inspection Date: 09/16/2019 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ®Yes ❑ No
If Yes, Explain.
North Durham WRF experienced several BOD violations, possibly caused by sampling tubing contamination.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number
INICI0I0I4 I7 Is 19 I7 I
MM/DD/YY
109 130 120
10.
.................................................................
Current Number of Significant Industrial. Users(SIUs)?...............................................................................................
11
11.
..............................................................................
Number of SIUs with No IUP,..or with an Expired IUP?..............................................................................................................................
0
12.
....................................................................................................................................................................................................................................................................................................
Number of SIUs Not Inspected by POTW in Last Calendar Year?
0
13.
....................................................................................................................................................................................................................................................................................................
Number of SIUs Not Sampled by POTW in Last Calendar Year?
0
14.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
0
15.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
0
16.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC with Pretreatment Schedule?
0
17.
....................................................................................................................................................................................................................................................................................................
Number of SIUs on Schedules?
1
18.
Current Number of Categorical Industrial Users.(C1Us)..?............................................................................................
4
19.
Number of C11tJs in SNC?
0
NC DWR Pretreatment Audit Form Revised: December 2016
Page 1

21. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element
in their File, complete with all supporting documents and PERCS Approval Letter, 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)
ND: 10/30/2017
SD: 10/30/2017
® Yes ❑ No
ND: 1/16/2018
SD: 1/16/2018
® Yes ❑ No
11/1/2022
Industrial Waste Survey (IWS)
4/7/2017
® Yes ❑ No
7/11/2017
® Yes ❑ No
4/30/2022
Sewer Use Ordinance (SUO)
12/21/2012
® Yes ❑ No
3/4/2013
® Yes ❑ No
Enforcement Response Plan (ERP)
2/14/2020
® Yes ❑ No
3/17/2020
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
3/29/2004
® Yes ❑ No
5/18/2004
® Yes ❑ No
Legal Authority (Sewer Use Ordinance-SUO)
22. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
❑ Yes ® No If yes, Please list these towns and/or areas. Durham County receives flow from the City under an inter -
jurisdictional agreement.
23. If yes to #22, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑ Yes ❑ No ® NA
A copy, if not already submitted, should be sent to Division.
24. If yes to #22, Have you had any trouble working with these towns or districts? ❑ Yes ❑ No ❑ NA
If yes, Explain.
25. Date of Last SUO Adoption by Local Council 12/26/2013
26. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
27. Did you send a copy of the ERP to your industries? ❑ Yes ® No
If no, POTW must send copy within 30 days. Updated ERP was sent SIUs on September 15, 2020.
28. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
❑ Yes ® No If yes, Explain.
29. List Industries under a Schedule or Order and Type of Schedule or Order
AW NC is under a consent order for zinc.
Resources
30. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
31
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
2 full time technicians dedicated to pretreatment, FOG, and
POTW's Pretreatment Program
®S ❑M ❑U
se to e.
Access to POTW Vehicles for
3 vehicles.
Sampling, Inspections, and
®S ❑M ❑U
Emergencies
Access to Operable Sampling
15 samplers.
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
Does the POTW have an adeauate data management system
to run the pretreatment nroaram? Yes n No
Explain Yes or No. AmeriTech Software.
NC DWR Pretreatment Audit Form Revised: December 2016
Page 2

32. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Sampling costs and surcharges.
Public Perception/ Participation
33. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain.
34. Has any one from the public ever requested to review pretreatment program files? ❑ Yes ® No
If yes, Explain procedure. If no, How would the request be addressed? Required to be in writing on letterhead. Director, city
attorney, and public affairs officer will be informed.
35. 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 no. how would the request be addressed?. Would be marked confidential, sealed, and stored in a separate
locked cabinet.
36. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
37. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
38. Were all industries in SNC published in the last notice? ® Yes ❑ No
Permitting (Industrial Waste Survey-IWS)
39a... How does the POTW become aware of new or changed Users? Chamber of Commerce contacts the POTW before a
user arrives. Weekly emails from City Permitting (on construction)
39b. 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
SILT?) Conversation, short form. Long form and inspection required if necessary.
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 Only Septage is accepted.
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) Designated discharge point and the capacity to take samples. Haulers are required to purchase
septage tickets from the City. Trucks are weighed, IDs checked, manifests submitted, area monitored by video
camera.
43. How does the POTW allocate its loading to industries? 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 allocations? ❑ Yes ® No
If yes, What parameters are over allocated?
45. If yes to #43, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
N/A
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter 30-40%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
48. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (for example: were only those pollutants
listed on the application limited; categorical parameters; NPDES Pollutants of Concern)
Federal guidelines, capacity to impact the POTW.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits ? Explain.
Federal/State guidelines, capacity to impact the POTW.
Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No
If yes, which industries? What was (will be) the outcome of the adjudication?
51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC. AmeriTech Software and compliance judgement sheets.
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all DWQ data? ❑ 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?
Federal/State criteria and the capacity to impact the POTW. Plan required if aggregate 1320 gallons of storage or 660
gallons for any one container.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Basic information: Correct contact information, responsible officials, who they are, process type.
56. How does the POTW decide where the sample point for an SIU should be located?
Preferably downstream of all process control and with no domestic. Segregated to the particular industry that uses it.
POTW is involved before users arrive as it is simpler to change a location on a blueprint than digging up pipe. Staff safety
is also taken into consideration.
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 ❑ No If yes, Explain. POTW lab tech knows sample locations, samplers
are run for the proper amount of time with the minimum of 100 ml/hour collected, sample bucket is swirled uniformly.
58. Who performs sample analysis for the POTW for Metals POTW, Enco(low level HO
Conventional Parameters POTW
Organics Enco, Lancaster (pharmaceutical), and Meritech (Toxticity)
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
POTW lab tech fills out all information (date/time collected/preservatives used), samples are placed in cooler and Chain of
Custody (in house or commercial labs) is left for the lab to pickup if applicable with the time relinquished.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® 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 (DMR)? ® YES ❑ NO DWQ 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) ? ® Yes ❑ No
If no, Who completes your HWA? Phone (_) --
62. Do you have plans to revise your HWA in the near future? ® 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. Plant construction.
63. In general, what is the most limiting criteria of your HWA? ❑Inhibition ® Pass Through ❑Sludge Quality
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ® No
Explain. Looking into more land for sludge disposal as current land available is being restricted. Plant upgrade will provide
more MAHL.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
P. Cormetech 2. AW NC
3. Corning
67. IUP Number
1036
loll
1030
68. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
69. Permit Expiration Date
3/31/2021
12/31/2022
3/31/2023
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
433.17
N/A
71. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
®Yes ❑ No
® Yes ❑ No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
® Yes ❑ NoI
® Yes ❑ No
® Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
a. ®Yes []No
a. ®Yes ❑No
a. ®Yes []No
b. If No, is One Needed? (See Inspection Form from POTW)
b. ❑Yes ❑No
b. ❑Yes ❑No
b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑No®N/A
F
®Yes❑No❑N/A
®Yes❑No❑N/A
Organic Management Plan (TOMP)?
75. a. Does File Contain Original Permit Review Letter from Division?
a. ®Yes []No
a. ®Yes ❑No
a. ®Yes []No
b. All Issues Resolved?
b.❑Yes❑No®N/A
b.❑Yes®No❑N/A
b.❑Yes❑No®N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
Sampling as Required by IUP, including Flow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes❑No®N/A
Sampling as Required by IUP, including Flow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes❑NoON/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/APTs❑NoN
7esONoON/A
file include process/dilution flows as Required by IUP?
80b. For categorical IUs with Production based limits, does file include
❑Yes❑NoON/A
❑Yes❑No®N/A
❑Yes❑No[D
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑NoON/A
®Yes ❑ No
❑Yes❑No®N/A
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
Reportin& Non -Compliance from SIU Sampling?
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑No®N/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
becoming aware of SIU limit violations in the POTW's sampling of SIU?
c.❑Yes❑No®N/A
c.®Yes❑No❑N/A
c.❑Yes❑No®N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑
Yes
®
No
❑
Yes
®No
❑
Yes
®No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
❑Yes❑No®N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
0Yes0No[9
❑Yes❑No®N/A
❑Yes❑No®N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑No[D
❑Yes❑No®N/A
❑Yes❑NoON/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 ®No
❑ Yes ® No
Information For You?
FILE REVIEW COMMENTS:
81 - AW NC had four daily maximum and two monthly average violation for zinc in January and February 2020.
85 - The POTW issued two NOVs for AW NC's zinc violations.
88 - AW NC was entered a consent order on February 20, 2020. The order would expire on August 31, 2020, but was extended to the end
of February 2021. AW NC has been in compliance with the order.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I N I C 1 0 1 0 1 4 1 7 1 5 1 9 1 7 I 1 09 1 30 1 20 1
1. Industry Inspected: Cormetech
2. Industry Address: 5000 International Drive, Durham NC 27712
3. Type of Industry/Product: Manufacturing/Environmental catalysts
4. Industry Contact: Lanette Plyler Title: Director of Environmental Health & Safety
Phone: [phone] Fax: [phone]
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 Comments:
The inspection was thorough, and met the Division's requirements.
Audit SUMMARY AND COMMENTS:
Audit Comments: The prouram is well managed.
Requirements: None
Recommendations: Pump station capacities should be taken into consideration when allocating flow to SIUs in the future.
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory® Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Cheng Zhang, RRO DATE: September 30, 2020
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7