NC0047597_Pretreatment Compliance Inspection_20221206

DocuSign Envelope ID: 9E812E88-684A-4335-8D23-F388A594B31A
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. Don Greeley
Director of Water Management
City of Durham
101 City Hall Plaza
Durham, NC 27701
NORTH CAROLINA
Environmental Quality
December 6, 2022
Subject: Pretreatment Compliance Inspection
City of Durham
South Durham WRF - NPDES Permit No. NC0047597
North Durham WRF - NPDES Permit No. NC0023841
Durham County
Dear Mr. Greeley:
On September 28, 2022, Cheng Zhang of the Raleigh Regional Office conducted a Pretreatment
Compliance Inspection of City of Durham's pretreatment program. The assistance given by Mr. Tyrone
Battle, the pretreatment coordinator, was greatly appreciated. The inspection report is attached.
Findings during the inspection were as follows:
1. There are 12 Significant Industrial Users (SIUs), 6 of which are also Categorical Industrial Users
(CIUs). It was noted that there were no SIU's in SNC for the two most recent semi-annual
periods.
2. The pretreatment inspection file review included Novo Nordisk (Permit No. 1041), Technicoat
(Permit No. 2013), and Alsco (Permit No. 2006). The files needed for review were available for
inspection, contained all the required elements and were in excellent condition. Both the SIU and
the POTW completed required monitoring during the first half of 2022. Novo Nordisk had one
acetone violation in March 2022. The POTW issued a Notice of Violation for the violation and
request the SIU to resample on April 22, 2022. Novo Nordisk resampled effluent acetone on
April 28, result was compliant. Technicoat and Alsco were compliant during the review period.
3. A review of the files containing the pretreatment program elements was conducted. These files
are up to date and well organized. Industrial Waste Survey was recently updated and submitted
to the Division on April 27, 2022. It is recommended that the City update the Long Term
Monitoring Plan (LTMP) by using the most recent PQLs for some parameters.
4. 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
Pretreatment inspection. It was noted that the POTW started monthly sampling in July 2021.
NOAD_E Q 3
oay,rorem or Environmental ou.i�
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office I 3800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: 9E812E88-684A-4335-8D23-F388A594B31A
The 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]).
Enclosure: City of Durham PCI Inspection Form
CC: Laserfiche
Tyrone Battle, City of Durham (Electronic copy only)
D_E
NORTH CARCLINA
gaparhnanl of Environmental quality
Sincerely,
—DocuSigned by:
Vann t,SSA, f. Iti 4VA/it,(,
"—B2916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

DocuSign Envelope ID: 9E812E88-684A-4335-8D23-F388A594B31A
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL QUALITY
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority (POTW) Name: City of Durham
2. Control Authority Representative(s): Tyrone Battle
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: September 30, 2020 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 ® NO
Order Type, Number, Parameters: Are Milestone Dates Being Met? ❑ YES ❑ NO
ICIS CODING
Main Program Permit Number
N1C10 10 14171519171
MM/DD/YY
I09I281221
7. Current Number Of Significant Industrial Users (SIUs)?
12
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 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
15. Current Number Of Categorical Industrial Users (CIUs)?
6
16. Number of CIUs 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 How are these Problems Being Addressed?
SD: mercury, TN (TP) annual load, 2021; ND: ammonia 5/21
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
either of the Last 2 Semi -Annual Periods? Not Been Published for
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
SNC for
SNC for
Not Pul
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 Permits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
LTMP/STMP FILE REVIEW:
/1 YES ❑ NO
❑ YES /1 NO
Limits: None
Reporting: None
lished: None
None
❑ YES aO
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
25. All LTMP 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 LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
NO
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

DocuSign Envelope ID: 9E812E88-684A-4335-8D23-F388A594B31A
28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element in
their files, complete with supporting documents and copy of 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)
SD: 10/30/2017
ND: 10/30/2017
Yes ❑ No
SD: 1/6/2018
ND: 1/6/2018
►/ Yes ❑ No
11/1/2022
Industrial Waste Survey (IWS)
4/27/2022
0 Yes ❑ No
7/11/2017
r Yes ❑ No
4/30/2022
Sewer Use Ordinance (SUO)
12/21/2012
/1 Yes ❑ No
3/4/2013
/1 Yes ❑ No
Enforcement Response Plan (ERP)
2/14/2020
/1 Yes ❑ No
3/17/2020
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
11/17/2021
/1 Yes ❑ No
4/20/2022
/1 Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. Novo Nordisk
2. Technicoat
3. Alsco
30. IUP Number
1021
2013
2006
31. Does File Contain Current Permit?
/1 Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
32. Permit Expiration Date
11/4/2025
7/31/2025
4/14/2023
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
439D
433
N/A
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
A Yes ❑ No
/1 Yes ❑ No
A Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
/1 Yes ❑ No
1 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. ►1Yes •No
b. •Yes ■ No
a. •Yes LNo
b. •Yes A No
a. •Yes ANo
b. •Yes L No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
❑ Yes ❑NoNN/A
®Yes❑No❑N/A
❑Yes❑NoNN/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. A Yes ■ No
b.❑Yes❑No❑N/A
a. ►N Yes ■ No
b.❑Yes❑No❑N/A
a. A Yes ■ No
b.❑Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
/1 Yes ❑ No
/1 Yes ❑ No
1 Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
A Yes ❑ No
/1 Yes ❑ No
A Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes❑NoNN/A
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
on time?
®Yes❑No❑N/A
NYes❑No❑N/A
❑Yes❑NoNN/A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑NOON/A
❑ Yes ❑NoNN/A
❑Yes❑NoNN/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
NYes ❑No❑N/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑ Yes ❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
44. a. Was the 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 within 30 days of becoming aware
of SIU limit violations in the POTW's sampling of the SIU?
a.®Yes❑No❑N/A
h.®Yes❑No❑N/A
c.❑Yes❑NoNN/A
a.❑Yes❑NoNN/A
b.❑Yes❑NoNN/A
c.❑Yes❑NoNN/A
a.❑Yes❑NoNN/A
b.❑Yes❑NoNN/A
c.❑Yes❑NoNN/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑
Yes
/1
No
❑
Yes
L
No
❑
Yes
/1
No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
NYes❑No❑N/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
50. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes❑NoNN/A
b.❑Yes❑NoNN/A
a.❑Yes❑NoNN/A
b.❑Yes❑NoNN/A
a.❑Yes❑NoNN/A
b.❑Yes❑NoNN/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
❑ Yes /1 No
❑ Yes r No
❑ Yes
I
No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

DocuSign Envelope ID: 9E812E88-684A-4335-8D23-F388A594B31A
FILE REVIEW COMMENTS:
41 & 42 — Alsco is not required to sample and report.
43a — Novo Nordisk had one acetone violation in March 2022.
44b — Novo Nordisk resampled acetone on April 28, result was compliant.
47 — POTW issued a NOV for Novo Nordisk's acetone violation.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
1NICI0I014171519171
1. Industry Inspected:
2. Industry Address:
3. Type of Industry/Product:
4. Industry Contact: Title:
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:
OVERALL SUMMARY AND COMMENTS:
Comments: The program is well managed.
Requirements: None
Recommendations: Update LTMP by using most recent PQLs for some parameters.
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
® Satisfactory ❑ Marginal ❑ UnSatisfactory
PCI COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: September 28, 2022
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3