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Home My WebLink AboutNC0047597_Pretreatment Audit_20240822Docusign Envelope ID: 9D9D9F16-38C5-4116-B179-F594468A671E ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Mr. John Young Assistant Director of Water Management City of Durham 101 City Hall Plaza Durham, NC 27701 Subject: Pretreatment Audit NORTH CAROLINA Environmental Quality August 22, 2024 City of Durham South Durham WRF - NPDES Permit No. NCO047597 North Durham WRF - NPDES Permit No. NCO023841 Durham County Dear Mr. Young: On July 30, 2024, Natalie Gorensek of Division of Water Resources Central Office, Cheng Zhang and Jesse Barnes of the Raleigh Regional Office (RRO) conducted a Pretreatment Audit of City of Durham's pretreatment program. The assistance given by Mr. Tyrone Battle, the Industrial Waste Control Manager, was greatly appreciated. The audit report is attached. Findings during the inspection were as follows: The city has twelve Significant Industrial Users (SIUs), six of which are also Categorical Industrial Users (CIUs). It was noted that no SIU was in Significant Non -Compliance (SNC) for the two most recent semi-annual periods. 2. The pretreatment audit file review included Freudenberg (Permit No. 1021), AISIN (Permit No. 1011), and BioMerieux (Permit No. 1023). The files needed for review were available for inspection, contained all the required information. 3. POTW and SIUs completed monitoring as required by the Industrial User Pretreatment Permits (IUPs) during the most recent semi-annual period. Freudenberg and BioMerieux were compliant in the first semi-annual period of 2024. AISIN had two zinc violations in January 2024, the City took proper enforcement against the violations as required by the Enforcement Response Plan. 4. During the audit, Ms. Battle inspected one of the SIUs, Freudenberg. The inspection was very thorough. 5. A review of the files containing the pretreatment program elements was conducted. These files were very well organized. Update of Headworks Analysis was submitted in November 2022, update of Industrial Waste Survey was submitted in February 2023, and these elements are in review by the Division. North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional Office 1 3800 Barrett Drive I Raleigh, North Carolina 27609 NORTH CAROLINA ^ 919.791.4200 n�,Mo E,Amnm W1 Q1K, Docusign Envelope ID: 9D9D9F16-38C5-4116-B179-F594468A671E 6. The review of Long Term Monitoring Plan (LTMP) data indicated that all locations were sampled with required frequencies, and all samples were analyzed using correct detection limits specified in the LTMP since last inspection. Thank you for your continued support of the Pretreatment Program. If you have any questions or comments, please call Cheng Zhang at (919) 791-4200 (or email: cheng.zhang@deq.n.gov). Sincerely, DocuSigned by: Vaan t,SSa f. 62916E6AB32144F... Vanessa E. Manuel, Assistant Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources Enclosure: City of Durham Pretreatment Audit Form Cc: Laserfiche Tyron Battle, City of Durham (electronic copy only) DE��5 North Carolina Department of Environmental Quality I Division of Water Resources 512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611 NORTH CAROLINA919.707.9000 nape .mo EnWromm�nfal qual Docusign Envelope ID: 9D9D9F16-38C5-4116-B179-F594468A671E 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: City of Durham 2. Control Authority Representative(s): Tyrone Battle 3. Title(s): Industrial Waste Control Manager 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.Battlendurhamnc.gov 5. Audit Date 07/30/2024 6. Last Inspection Date: 09/28/2022 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 INIC101014 I7 Is 19 I7 I MM/DD/YY 107 130 124 NC DWR Pretreatment Audit Form Revised: December 2016 Page 1 Docusign Envelope ID: 9D9D9F16-38C5-4116-B179-F594468A671E 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: 11/1/2022 SD: 11/1/2022 ® Yes ❑ No ND: 1/16/2018 SD: 1/16/2018 ® Yes ❑ No Industrial Waste Survey (IWS) 2/24/2023 ® Yes ❑ No 7/11/2017 ® Yes ❑ No 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) ND: 11/17/2022 SD: 6/5/2023 ® Yes ❑ No ND: 4/20/2022 SD: 6/13/2023 ® 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 in July 2024. 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. One or more positions would be better. 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 Dretreatment Droaram? 15ZI Yes n No NC DWR Pretreatment Audit Form Revised: December 2016 Page 2 Docusign Envelope ID: 9D9D9F16-38C5-4116-B179-F594468A671E Explain Yes or No. AmeriTech Software. 32. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. Sampling costs and surcharges, permitting fees. 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 made through the City's Public Information Officer. 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?. Requests will be determined for confidential status with consultation with the City Attorney. Once determined confidential, the information 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. From City Permitting (on construction) and City Planning Department. 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 SIU?) Conversation, short form. Long form and inspection/permit application 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 use 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 10-15% 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) NC DWR Pretreatment Audit Form Revised: December 2016 Page 3 Docusign Envelope ID: 9D9D9F16-38C5-4116-B179-F594468A671E Federal guidelines, capacity to impact the POTW. 49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits ? Explain. FederaUState 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 SILT 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 SILT: ® 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, Eurofins (low level Hg) Conventional Parameters POTW Organics 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. 60b. 60c. 60d. 60e. 60f. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO DWQ Inspector, verify yourself! If NO to any above, list violations Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ® YES ❑ NO If yes, which ones? Eliminated: Added: TDS for NDWRF 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 ❑More LTMP data available ❑Resolve over allocation ❑5 year expiration Explain. NDWRF NPDES Permit was renewed 6/1/2024. ❑NPDES limits change ®Other NC DWR Pretreatment Audit Form Revised: December 2016 Page 4 Docusign Envelope ID: 9D9D9F16-38C5-4116-B179-F594468A671E 63. In general, what is the most limiting criteria of your HWA? ❑Inhibition ® Pass Through El 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. 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? PFAS and silver. NC DWR Pretreatment Audit Form Revised: December 2016 Page 5 Docusign Envelope ID: 9D9D9F16-38C5-4116-B179-F594468A671E INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION) 66. User Name 1. Freudenberg 2. AISIN 3. BioMerieux 67. IUP Number 1021 1 1011 1 1023 68. Does File Contain Current Permit? ® Yes ❑ No ® Yes ❑ No ® Yes ❑ No 69. Permit Expiration Date 7/31/2027 12/31/2027 6/30/2026 70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 410.11 433.17 N/A 71. Does File Contain Permit Application Completed Within One Year Prior ® Yes ❑ No Fff7Ts ❑ No ® Yes ❑ No to Permit Issue Date? 72. Does File Contain Inspection Completed Within Last Calendar Year? I ® Yes ❑ No ® 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 ®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 I 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 i Sampling as Required by IUP, including Flow? I 77. Does File Contain POTW Sampling Chain -Of -Custody Forms? I ® Yes ❑ No7j ® Yes ❑ No 11 ® Yes ❑ No 78. During Most Recent Semi -Annual Period, Did SIU Complete its ❑Yes❑No®N/A F ®Yes❑No❑N/A ®Yes❑No❑N/A 1 Sampling as Required b IUP, includingFlow? 79. During Most Recent Semi -Annual Period, Did SIU submit all reports on ❑Yes❑No®N/A F ®Yes❑No❑N/A ❑Yes❑NoON/A time? 80a. For categorical IUs with Combined Wastestream Formula (CWF), does ❑Yes❑NoON/A ❑Yes❑No®N/A ❑Yes❑NoON/A file includeprocess/dilution flows as Required by IUP? 80b. For categorical lUs 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 Re ortin Non -Compliance from SIU Sampling? 83. a. Was POTW Notified by SILT (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 c.❑Yes❑No®N/A c.❑Yes❑No®N/A c.❑Yes❑No®N/A becoming aware of SIU limit violations in the POTW's sampling of SIU? 84. During Most Recent Semi -Annual Period, Was SIU in SNC? i ❑ Yes ®No ❑ Yes ®No ❑ Yes ®No 85. During Most Recent Semi -Annual Period, Was Enforcement Taken as 0Yes0No[9 ®Yes❑No❑N/A ❑Yes❑NoON/A Specified in POTW's ERP (NOVs, Penalties, timing, etc.)? 86. Does File Contain Penalty Assessment Notices? 0Yes0No[9 ❑Yes❑No[El ❑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 - AISIN had two zinc violations in January 2024. 85 - The City issued a NOV to AISIN for the zinc violations on March 15, 2024. NC DWR Pretreatment Audit Form Revised: December 2016 Page 6 Docusign Envelope ID: 9D9D9F16-38C5-4116-B179-F594468A671E INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY I N I C I 0 I 0 1 4 17 15 19 17 I 107 130 124 1. Industry Inspected: Freudenberg 2. Industry Address: 3500 Industrial Drive, Durham NC 27704 3. Type of Industry/Product: Texile/Nonwowen fiber 4. Industry Contact: Jim Fitz Title: HSE Manager Phone: 919-479-7463 Fax: 919-479-7456 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 program is well managed. Requirements: None Recommendations: None. NOD: ❑ Yes ® No NOV: ❑ Yes ® No QNCR: ❑ Yes ® No POTW Rating: Satisfactory ® Marginal ❑ Unsatisfactory ❑ Audit COMPLETED BY: Cheng Zhang, Jesse Barnes RRO: Natalie Gorensek, NC DWR DATE: July 30, 2024 NC DWR Pretreatment Audit Form Revised: December 2016 Page 7