NC0047597_Pretreatment Compliance Inspection_20170613

Water Resources
ENVIRONMENTAL QUALITY
June 13, 2017
Ms. Vicki Westbrook
Assistant Director of Water Management
City of Durham
101 City Hall Plaza
Durham, NC 27701
ROY COOPER
cownor
MICHAEL S. REGAN
Secretory
S. JAY ZIMMERMAN
olmdor
RECEIVEMCDENWR
JUN 16 2017
Subject: Pretreatment Compliance Inspection Water Quality
City of Durham Permitting Section
South Durham WRF - NPDES Permit No. NCO047597
North Durham WRF - NPDES Permit No. NCO023841
Durham County
Dear Mr. Hicks:
On May 26, 2017, 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 13 Significant Industrial Users (SIUs), 5 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 Merck Vaccine Manufacturing Facility (Permit
No. 103 8). 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 second half of 2016. No limit violations were noted. It was noted that the
SIU has not been submitting monthly flow reports to the POTW (flow data were collected and
kept at the SIU, no flow limit exceedance occurred). In order to appropriately judge compliance
on the flow limit stipulated in the Permit, the POTW shall request the SIU to submit monthly
flow reports before the due date specified in the Permit.
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.
Division of Water Resources, Raleigh Regional Office, Water Quality Operations Section http.//deq ne gov/about/dlvisions/water-resources
1628 Mail Service Center, Raleigh, NC 27699-1628 Phone [phone]
Location. 3800 Barrett Drive, Raleigh, NC 27609 Fax. [phone]

4. 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 Pretreatment inspection.
5. As part of the inspection, the inspector watched Mr. Battle conducting a SIU inspection at Merck
Durham Vaccine Manufacturing Facility (Permit No. 1038), the inspection was thorough and
covered all required areas.
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]).
incere ,
Danny Smith
Regional Supervisor
Raleigh Regional Office
Enclosure: 2017 City of Durham PCI Inspection Form
CC Deborah Gore, DWQ - PERCS Unit
Central Files
Cheng Zhang, RRO
Tyrone Battle, City of Durham

J
NORTH CAROLINA DIVISION OF WATER QUALITY
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION [Complete Prior To PCI• Review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: City of Durham
2. Control Authority Representative(s): Tyrone Battle
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 9/24/2015 Inspection Type (Check One): ❑ PCI ® Audit
5 Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)9 ® 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
PCS CODING
Trans Code Main Program Permit Number MM/DD/YY
INTI INIC10101417151917J 1051261171
Inspec Type Inspector Fac. Type
1 P J L—S J L -1—i
(DTIA) (TYPI)
(INSP)
(FACC
7. Current Number Of Significant Industrial Users (SIUs)?
13
SNS
8. Current Number Of Categorical Industrial Users (CIUs)?
5
CNS
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 Enter the Higher Number of 9 or 10
0
NOIN
12 Number of SIUs With No IUP, or With an Expired IUP
0
NOCM
13. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2
0
PSNC
Semi -Annual Periods (Total Number of SIUs in SNC)
14 Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods
0
MSNC
15 Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods
0
SNPS
16. Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2
0
Semi-annual Periods
POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations? ❑ YES ® NO
If Yes, What are the Parameters and How are these Problems Being Addressed?
North Durham WRF failed aquatic toxicity test October 2012
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. None
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for Reporting. None
Public Notice? (May refer to PAR if Excessive SIUs in SNC) Not Published- N/A
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? None
21. Are Any Permits Or Civil Penalties Currently Under Adjudication? If Yes, Which [-]YES ®NO
Ones?
LTMP/STMP 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 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/STMP effluent data reported on Discharge Monitoring Report? ® YES ❑ NO DWQ Inspector, please verify yourself
26. IfNO 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-
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW- Please review POTW files, veWPOTW Has copy o rogramElementin
their files, complete with supporting documents and copy of PERCS Approval
Program Element Last Submittal
Date In file?
Letter, and dates consistent with rro
Last Approval
Date In file
ram info,
Date Next Due,
If Applicable
Headworks Analysis (HWA)
SD: 11/1/2012
® Yes ❑ No
SD: 3/12/2013
® Yes ❑ No
11/1/2017
Industrial Waste Survey (IWS)
ND: 11/1/2012
4/7/2017
® Yes ❑ No
ND: 3/12/2013
3/12/2013
® Yes ❑ No
Sewer Use Ordinance (SUO
12/21/2012
® Yes ❑ No
3/4/2013
®Yes ❑ No
Enforcement Response Plan RP
9/29/2010
® Yes ❑ No
11/23/2010
®Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
Long Term Monitoring Plan (LTMP)
3/29/2004
® Yes ❑ No
1 5/18/2004
1 ®Yes ❑ No
-vrr v v'v1tT W rz TT TP FT P RFVTF.WS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. Merck 2.
3.
1038
30. IUP Number
® Yes ❑ No
31. Does File Contain Current Permit?
3/31/2021
32. Permit Expiration Date
439.D
33. Categorical Standard Applied I.E. 40 CFR, Etc Or N/A
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
® Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
a. ®Yes ❑No
b. If No, is One Needed See Inspection Form from PO
b ❑Yes❑No®N/A
❑Yes❑NoON/A
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan TOMP ?
38. a Does File Contain Original Permit Review Letter from the Division?
a. ®Yes []No
b. All Issues Resolved?
b ❑Yes❑No®N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑ No
its Sampling as Required by IUP, including flow?
40. Does File ContainPOTW Sampling Chain -Of -Custody Forms?
FN Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Yes❑No❑N/A
Sampling as Required by IUP, including flow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
❑Yes®No❑N/A
on time?
42a. For IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
categorical
file includeprocess/dilution flows as Required by ICJP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑No®N/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes®No❑N/A
All Reporting Non -Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a ❑Yes❑No®N/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
b ❑Yes❑No®N/A
c. If applicable, Did POTW resample within 30 days of becoming aware
c ❑Yes❑No®N/A
of SIU limit violations in the POTW's sampling of the SIU?
i LJ es ® No
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑No®N/A
as Specified in the POTW's ERP OVs, Penalties, timing, etc.)?
48. Does the File Contain Penalty Assessment Notices?
Collection?
❑Yes❑No®N/A
❑Yes❑No®N/A
49 Does The File Contain Proof Of Penalty
50. a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑No®N/A
I
IF 1
b. Is SIU in Compliance with Orders
b ❑Yes❑No®N/A
® No
51 Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes
I=
Requested Information For You?
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

FILE REVIEW COMMENTS:
#41b — Merch has not been submitting monthly flow reports to the POTW. Flow data is kept by the SIU. Daily flow is way lower that
the flow limit stipulated in the IUP.
INDUSTRY INSPECTION PCS CODING:
Trans Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type
LNJI N1 C1010 1 4 17 1 5 19 1 7 I1051261171 D(T�YIP j ( S) (F
1. Industry Inspected: Merck Durham Vaccine Manufacturing Facility
2. Industry Address: 5323 Old Oxford Road Durham NC
3. Type of Industry/Product: Pharmaceurical/Vaccmes
4. Industry Contact: Jim Kenny & Jerry Revis Title: Senior EHS Specialist
Phone: [phone] Fax:
5. Does the POTW Use the Division Model Inspection Form or Equivalent? ® YES ❑ NO
6. Did the POTW Contact Conduct the Followmg Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview ® YES ❑ NO
B. Plant Tour ® YES ❑ NO
C. Pretreatment Tour OYES ❑ NO
D. Sampling Review ®YES ❑ NO
E. Exit Interview ® YES ❑ NO
Industrial Inspection Comments:
evident that the POTW representative has good working relationship with SIU staff.
The inspection was very thorough. It is
OVERALL SUMMARY AND COMMENTS:
Comments: The pretreatment program at City of Durham is well managed.
Requirements: POTW shall request applicable SIUs to submit monthly flow reports to judge compliance on now limitation.
Recommendations:
NOD: ❑ YES ®NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory® Marginal ❑ UnSatisfactory ❑
PCI COMPLETED BY: Cheng Zhang DATE: Mav 26.2017
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3