NC0026051_Pretreatment Audit_20211228

DocuSign Envelope ID: C68F0722-EB59-4470-AEE2-FD48946334D3
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Via e-mail: [e-mail]
NORTH CAROLINA
Environmental Quality
December 28, 2021
Ms. Stephanie Brixey, Deputy Director
Department of Engineering and Environmental Services
Durham County
5926 NC Hwy 55 E
Durham, NC 27713
Subject: Pretreatment Audit
Durham County Triangle WWTP
NPDES Permit No. NC0026051
Durham County
Dear Ms. Brixey:
On September 15, 2021, Cheng Zhang of the Raleigh Regional Office conducted an audit of
Durham County's pretreatment program. The assistance given by Ms. Amy Moore, the
Compliance Manager, and Ms. Laura Melton, the Pretreatment Project Coordinator, was greatly
appreciated. The inspection report is attached. Findings during the inspection were as follows:
1. There are 13 Significant Industrial Users (SIUs) discharging to the WWTP, 12 of which
are also Categorical Industrial Users (CIUs). It was noted that United Therapeutics was
in Significant Non -Compliance (SNC) for acetone violations during the two most recent
semi-annual periods.
2. The pretreatment inspection file review included Astra Zeneca (Permit No. DC-078),
Cintas (Permit No. DC-037) and Micross (Permit No. DC-085). The files needed for
review were available for inspection, contained all the required elements and were in
excellent condition. In the first half of 2021, Astra Zeneca and Micross were in
compliance. Cintas had one oil & grease violation, the POTW took enforcement as
required the Enforcement Response Plan.
3. A review of the files containing the pretreatment program elements was conducted. All
files were available, up to date, and well organized.
NOR�D_E
�eeabnenl al EnNrvnmenlel5uelily
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: C68F0722-EB59-4470-AEE2-FD48946334D3
4. Long Term Monitoring Plan (LTMP) data since the last inspection were reviewed, it was
noted that all parameters were sampled at required locations and analyzed with required
detection levels. LTMP data was well organized and maintained.
5. As part of the audit, the inspector watched Ms. Melton conduct an inspection of one of
the County's SIUs, Micross. The inspection was very thorough. It was evident that Ms.
Melton has good relationship with the industry representative and broad knowledge of the
SIU's pretreatment operation.
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,
EDocuSigned by:
htlAA,SSA, f. gitaIAdtid,
B2916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Attachments: PT Audit Form
Cc: Central Files w/attachment (Laserfiche)
Raleigh Regional Office w/attachment
Amy Moore, City of Raleigh (electronic copy only)
1:11
NORM CAROLINA ���
IN.1.1 1 of EnWrpnmenUl aunlii
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office r 3800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: C68F0722-EB59-4470-AEE2-FD48946334D3
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resources
ENVIRONMENTAL QUALITY
Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Durham County- Triangle WWTP
2. Control Authority Representative(s): Amy Moore:, Laura Melton
3. Title(s): Compliance Manager; Pretreatment Project Coordinator
4. Address of POTW:
Mailing 5926 Highway 55 East
City Durham Zip Code 27713
Phone Number [phone] Fax Number [phone] E-Mail ajmoore(a,dconc.gov
5. Audit Date 09/15/2021
6. Last Inspection Date: 03/04/2020 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.
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
1N1C101012 16 10 15 11 1
10. Current Number of Significant Industrial Users (SIUs)?
11. Number of SIUs with No IUP, or with an Expired IUP?
MM/DD/YY
I 09 I 15 I 21 I
13
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?
1
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?
0
18. Current Number of Categorical Industrial Users (CIUs)?
19. Number of CIUs in SNC?
12
1
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20. 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)
3/16/2018
a4 Yes ❑ No
5/2/2018
❑ Yes ❑ No
4/1/2023
Industrial Waste Survey (IWS)
3/31/2021
I4 Yes ❑ No
5/5/2021
❑ Yes ❑ No
5/4/2026
Sewer Use Ordinance (SUO)
12/20/2012
/4 Yes ❑ No
4/3/2013
❑ Yes ❑ No
Enforcement Response Plan (ERP)
2/11/2020
/4 Yes ❑ No
2/13/2020
❑ Yes ❑ No
Long Term Monitoring Plan (LTMP)
9/9/2013
0 Yes ❑ No
9/9/2013
❑ 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 jurisdiction?
® Yes ❑ No If yes, Please list these towns and/or areas. City of Durham
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ® 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 with these towns or districts? ❑ Yes ® No ❑ NA
If yes, Explain.
24. Date of Last SUO Adoption by Local Council 3/11/2013
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? ❑ 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, etc?
❑ 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=Mareinal U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
a S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
CS ❑M ❑U
Access to Operable Sampling
Equipment
0 S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
0 S ❑M ❑U
Reference Materials
►1S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
0 S ❑M ❑U
Computer Equipment (Hardware and
Software)
0 S ❑M ❑U
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30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. CAPTAINS Pretreatment software
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Pretreatment fees and surcharge fees (BOD, TSS, TKN, and TP)
Public Perception/ Participation
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain.
33. 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? A time would be scheduled for the member of the public
to come in and review files. POTW staff would be present during the review and would make any copies requested as
necessary. Confidential information would not be available for review.
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 no how would the request be addressed? Any information strictly proprietary/trade secret would be
considered confidential. POTW would follow what is defined in their SUO. Information would be placed in a sealed
envelope, stamped and placed in a locked filing cabinet. The request for information to be deemed confidential must be
done up front.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
37. Were all industries in SNC published in the last notice? ® Yes ❑ No
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? From development review group; check project
registry & news; all industries are required to complete short industrial survey 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
SIU?) Review IWS to determine if the user is a SIU or CIU. The POTW has a SOP for local users which are issued
permits if discharging 1% of the County's MAHL.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes No If Yes, How many are there? One
Please list each site and how it is permitted, if applicable. Groundwater remediation received from IBM. Controls are
embedded in the facility's SIU permit.
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) N/A
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? El Yes ® No
If yes, what parameters are over allocated?
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 / safety? ® Yes El No
If yes, what percentage of each parameter 10%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) El Yes ® No
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DocuSign Envelope ID: C68F0722-EB59-4470-AEE2-FD48946334D3
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)
Categorical parameters, POCs, local IU SOP, LTMP parameters
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Minimum requirements. Monitoring is increased for new permit holders and those facilities having issues with POCs.
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. Captains software for limit violations; reporting compliance is
judged based on postmark dates of reports.
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all Division 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?
Those that store bulk chemicals. Currently all SIUs have a plan as well as some local IUs.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
POTW has a checklist based on EPA guidance.
56. How does the POTW decide where the sample point for an SIU should be located?
Ideally, a categorical process only sample point, with a separate combined sampling site for local limits. Located
downstream of process and pretreatment units.
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. The installation of monitoring manholes is
required. POTW has a SOP for sampling and staff go out to permit holders to monitor the sampling performed by the
contracted labs.
58. Who performs sample analysis for the POTW for Metals Meritech
Conventional Parameters Meritech
Organics Meritech
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Both contract lab and in house COCs have sample ID, location, date, time, type of sample, parameters, and persons who
collect/analyze the sample
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 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) ? ® 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
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UMore LTMP data available UResolve over allocation ®5 year expiration ❑Other
Explain.
63. In general, what is the most limiting criteria of your HWA? ❑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. Final sludge will be composted instead of land applied,
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No.
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DocuSign Envelope ID: C68F0722-EB59-4470-AEE2-FD48946334D3
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Astra Zeneca
2. Cintas
3. Micross
67. IUP Number
DC-078
DC-037
DC-085
68. Does File Contain Current Permit?
0 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
69. Permit Expiration Date
12/31/2021
11/1/2022
10/20/2024
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
439 D&E
N/A
469 A
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
/1 Yes ❑ No
0 Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
II Yes ❑ No
/1 Yes ❑ No
A Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. ►Yes •No
b. ■Yes MN()
a. ►Yes •No
b. •Yes MN()
a. ►Yes •No
b. •Yes MN()
Certification, Does File Contain a Toxic
(TOMP)?
❑Yes❑NoON/A
❑ Yes ❑No®N/A
❑Yes❑NoON/A
74. For 40 CFR 413 and 433 TTO
Organic Management Plan
75. a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. ►Yes •No
b.❑Yes❑No❑N/A
a. Yes •No
b.❑Yes❑No❑N/A
a. ►Yes •No
b.❑Yes❑No❑N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
Sampling as Required by IUP, including Flow?
L Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
i1 Yes ❑ No
A Yes ❑ No
/1 Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
Sampling as Required by IUP, including Flow?
/1 Yes ❑ No
a Yes ❑ No
/1 Yes ❑ No
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
time?
Al Yes ❑ No
/1 Yes ❑ No
A Yes ❑ No
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑NoON/A
❑ Yes ❑NoON/A
❑Yes❑NoON/A
80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑No®N/A
❑Yes❑NOON/A
❑Yes❑No®N/A
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Limits Non -Compliance from Both POTW and SIU Sampling?
❑ Yes ❑NoON/A
®Yes❑No❑N/A
❑Yes❑NoON/A
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting Non -Compliance from SIU Sampling?
❑Yes❑NoON/A
❑ Yes ❑NOON/A
❑Yes❑NoON/A
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
Monitoring Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
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?
a.❑Yes❑No®N/A
b.❑Yes❑NoEIN/A
c.❑Yes❑No®N/A
a.®Yes❑No❑N/A
b.®Yes❑No❑N/A
c.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
c.❑Yes❑No®N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑ Yes 1 No
❑ Yes /1 No
❑ Yes 1 No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
❑Yes❑NoON/A
® Yes ❑No❑N/A
❑Yes❑NoON/A
86. Does File Contain Penalty Assessment Notices?
❑Yes❑No ON/A
❑ Yes ❑No®N/A
❑Yes❑NoNN/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑NoON/A
❑Yes❑No®N/A
❑Yes❑No®N/A
88. a. Does File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
❑ Yes Al No
❑ Yes i1 No
❑ Yes A No
FILE REVIEW COMMENTS:
81 — Cintas had one oil & grease violation in June 2021.
85 — POTW issued a NOV for Cintas's oil & grease violation on July 23, 2021.
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DocuSign Envelope ID: C68F0722-EB59-4470-AEE2-FD48946334D3
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INICIO I O 1 2 16 I o 1 5 11 I 109 115 121 I
1. Industry Inspected: Micross
2. Industry Address: 3021 E Cornwallis Rd building 1, Durham, NC 27709
3. Type of Industry/Product: Electronics/semiconductor products
4. Industry Contact: Giao Nguyen Title: Public Safety Officer Phone: [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 Comments:
POTW representative conducted a thorough inspection.
Audit SUMMARY AND COMMENTS:
Audit Comments: The program is well managed
Requirements: None
Recommendations:
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory
Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: 9/15/2021
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