NC0026051_Pretreatment Compliance Inspection_20171019

J
Wester Resources
ENVIRONMENTAL QUALITY
October 19, 2017
Ms. Stephanie Brixey
Compliance Manager
Durham County Utilities Division
5926 NC Highway 55 East
Durham, NC 27713
Subject: Pretreatment Compliance Inspection
Durham County — Triangle WWTP
NPDES Permit No. NCO026051
Durham County
Dear Ms. Brixey:
ROY COOPER
cmwmr
MICHAEL S. REGAN
Secrefsry
S. JAY ZIMMERMAN
Dirwor
NOV 17 2017
i�erlllitdE13� �;;ct000
On September 25, 2017, Cheng Zhang of the Raleigh Regional Office conducted a Pretreatment
Compliance Inspection of Durham County's pretreatment program. The assistance given by you and
Ms. Laura Melton, the Pretreatment Program 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, 12 of which are also Categorical
Industrial Users (CIUs). It was noted that no SIUs were in Significant Non -Compliance (SNC)
during the last two semi-annual period.
2. The pretreatment inspection file review included Biogen (Permit No DC -080), Micross (Permit
No. DC -085) and Novan (Permit No. DC -084). The files needed for review were available for
inspection, contained all the required elements and were in excellent condition. All three SIUs
were in compliance with permit requirements during the first six-month period of 2017.
3. A review of the files containing the pretreatment program elements was conducted. All files
were available and well organized. Please be reminded that update of Headwork Analysis is due
April 1, 2018.
4. Long Term Monitoring Plan (LTMP) data 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.
Division of Water Resouices, Raleigh Regional Office, Water Quahty Operations Section http //deq nc gov/aboutldivisions/water-resources
1628 Marl Service Center, Raleigh, NC 27699-1628 Phone [phone]
Location 3800 Barrett Drive, Raleigh, NC: 27609 Fax [phone]

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]).
S ncer ly,
Danny Smi
Surface Water Protection Supervisor
Raleigh Regional Office
Enclosure 2017 Durham County PCI Inspection Form
CC Monti Hassan, DWR - PERCS Unit
Central Files
Cheng Zhang, RRO

Nr'.0 NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
'',Voter Rew rces
' VINOfIMLN 11L WAL' I
BACKGROUND INFORMATIONJMrnplete Prior To PCI; Review Program Info Database Sheet(s)1
1 Control Authority (POTW) Name: Durham County
2 Control Authority Representative(s) Stephanie Brixey; Laura Melton
3 Title(s) Compliance Manager; Pretreatment Coordinator
4 Last Inspection Date- July 27, 2016 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
ICIS CODING
Main Program Permit Number
I N I C 1 0 10 12161015111
Are Milestone Dates Being Met? ❑ YES ❑ NO
MM/DD/YY
1 09 1 251 17 1
7 Current Number Of Significant Industrial Users (SIUs)9
13
8. Number of SIUs With No IUP, or With an Expired IUP9
0
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year9
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 Schedules9
I-
15 Current Number Of Categorical Industrial Users (CIUs)?
12
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?
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 SNC for
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for
Public Notice? (May refer to PAR if Excessive SIUs in SNC) Not Put
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 Adjudication9 If Yes, Which
Ones
[]YES ® NO
❑ YES ® NO
Limits- None
Reporting None
dished- None
None
[]YES ® NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies9 ® YES ❑ NO
23 Are Correct Detection Levels being used for all LTMP/STMP Monitorings ® 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 Division Inspector, please verify yourselfl
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 ones9 Eliminated. Added
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

✓ 28. PRETREATMENT PROGRAM ELEMENTS REVIEW - Please review POTW files, verify POTW has copy of Program Element in
tl,Pir file e rmmn1PtP with eiinnnrtino rinrnmente anrd rnnv of PFR C..S Annrnvnl T etter. and Antes cnnslStent with Program Info
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
4/19/2014
® Yes ❑ No
7/11/2014
® Yes ❑ No
4/1/2018
Industrial Waste Survey (IWS)
3/14/2016
® Yes ❑ No
5/31/2016
® Yes ❑ No
4/1/2021
Sewer Use Ordinance (SUO)
12/20/2012
® Yes ❑ No
4/3/2013
® Yes ❑ No
❑ Yes ® No
Enforcement Response Plan (ERP)
1/17/2013
® Yes ❑ No
4/3/2013
® Yes ❑ No
❑Yes❑NoEN/A
Long Term Monitoring Plan (LTMP)
10/8/2013
® Yes ❑ No
9/9/2013
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU
29 User Name 11 1 Biogen 11 2 Micross JF3 No -van
30 IUP Number
31. Does File Contain Current Permit9
32 Permit Expiration Date
33 Categorical Standard Applied (I E 40 CFR, Etc) Or N/A
34 Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date9
35 Does File Contain an Inspection Completed Within Last Calendar Year9
36 a. Does the File Contain a Slug/Spill Control Plan
b If No, is One Needed? (See Inspection Form from POTW)
37 For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)9
38 a Does File Contain Original Permit Review Letter from the Division
b All Issues Resolved?
39 During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
40 Does File Contain POTW Sampling Chain -Of -Custody Forms9
41 During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
41b During the Most Recent Semi -Annual Period, Did SIU submit all reports
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUPC
42b For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP9
43a During the Most Recent Serm-Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling9
43b During the Most Recent Senn -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
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
46 During the Most Recent Semi -Annual Period, Was the SIU in SNC?
47 During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc )?
48 Does the File Contain Penalty Assessment Notices?
49 Does The File Contain Proof Of Penalty Collection
50 a Does the File Contain Any Current Enforcement Orders?
b Is SIU in Compliance with Order?
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
DC -080 DC -085 I DC -084
Yes ❑ No ® Yes ❑ No 11 ® Yes ❑ No
8/23/2020 10/20/2019 9/31/2018
439 D&E 469 A 439 E
Yes ❑ No 11 ® Yes ❑ No IF ® Yes ❑ No
® Yes U No I Z Yes U No I L�j Yes L—J No
a ❑Yes ❑No a. ❑Yes ❑No a ❑Yes ❑No
b ❑Yes ❑No I b ❑Yes ❑No b ❑Yes ❑No
❑Yes❑NoNN/A ®Yes❑No❑N/A 11 ❑Yes❑NoNN/A
a NYes ❑No I a EYes ❑No 11 a NYes ❑No
b ❑Yes❑No❑N/A b ❑Yes❑No❑N/A 11 b ❑Yes❑No❑N/A
M Yes ❑ No FM —Yes ❑ No 11 ® Yes ❑ No
EYes❑No❑N/A
NYes❑No❑N/A
EYes❑No❑N/A
NYes❑No❑N/A
EYes❑No❑N/A
EYes❑No❑N/A
NYes❑No❑N/A
NYes❑No❑N/A
❑Yes❑NOEN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑YeS❑NOEN/A
❑YeS❑NONN/A
❑Yes❑NoEN/A
❑Yes❑NOEN/A
❑YesONOEN/A
❑YeS❑NOEN/A
❑YeS❑NONN/A
a ❑Yes❑NoNN/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
a ❑Yes❑No®N/A
b ❑Yes❑No®N/A
c ❑Yes❑No®N/A
❑ Yes ® No
❑ Yes ® No
❑ Yes ® No
❑YesONOEN/A
FYes❑NoNN/A
FYes❑N oON/A
❑Yes❑NoEN/A
❑Yes❑NOEN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
11 ❑Yes❑NoNN/A
a ❑Yes❑No®N/A a ❑Yes❑No®N/A a ❑Yes❑No®N/A
b ❑Yes❑No®N/A b ❑Yes❑No®N/A b ❑Yes❑No®N/A
❑ Yes M No 11 ❑ Yes ® No ❑ Yes ® No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

FILE REVIEW COMMENTS:
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
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 Thoroughly9
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: None
NOD: [—]YES ®NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ® Marginal ❑ UnSatisfactory ❑
PCI COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: September 25, 2017
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3