NC0029033_Compliance Evaluation Inspection_20181008

ROY COOPER
Governor
MICHAEL S. REGAN
"!- Secretary
;"14:f.91„ LINDA CULPEPPER
Interim Director
Water Resources
ENVIRONMENTAL QUALITY
October 8, 2018
Mr. Robert Massengill, PE RECEIVED/DENRIDWR
Public Utilities Director
City of Raleigh 0 C T 10 2018
Pia-Box 590
Raleigh, NC 27602 Water Resources
Permitting Section
Subject: Pretreatment Compliance Inspection
City of Raleigh
Neuse River WWTP -NPDES Permit No. NC0029033
Little Creek WWTP -NPDES Permit No.NC0079316
Wake County
Dear Mr. Massengill: -
On August 28, 2018, Cheng Zhang of the Raleigh Regional Office conducted a Pretreatment
Compliance Inspection of City of Raleigh's pretreatment program. The assistance given by Mr. Ryan
Faw, the industrial pretreatment coordinator, was greatly appreciated. The inspection report is attached.
Findings during the inspection were as follows:
1. There are 15 Significant Industrial Users (SIUs) discharging, 13 of which are also Categorical
Industrial Users (CIUs). It was noted that no SNS were in Significant Non-Compliance (SNC)
for the two most recent semi-annual periods.
2. The pretreatment inspection file review included Xellia Pharmaceuticals (Permit No. CARD),
Alsco (Permit No. SERV) and GlaxoSnmithKline (Permit No. GLAX). 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 during the most recent semi-annual period.
3. A review of the files containing the pretreatment program elements was conducted. All files
were available and well organized. Headworks Analysis for both plant was updated recently.
Industrial Waste Survey was also updated and approved in early 2018.
4. Long Term Monitoring Plan (LTMP) and STMP data for both plants were reviewed, it was noted
that all parameters were sampled at required locations and analyzed with required detection
levels. •
Division of Water Resources,Raleigh Regional Office,Water Quality Operations Section http://portal ncdenr.org/web/wq/aps
1628 Mail Service Center,Raleigh,NC 27699-1628 Phone.[phone]
Location: 3800 Barrett Drive,Raleigh,NC 27609 Fax [phone]

e
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]).
ri
ri''
, 1/'
7 Danny Smit
Surface Water Protection Supervisor
Raleigh Regional Office
Enclosure. 2018 City of Raleigh PCI Inspection Form
CC Monti Hassan,DWR-PERCS Unit
Central Files
Cheng Zhang,RRO
Ryan Faw,City of Raleigh

, - NORTH CAROLINA 'VISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
WRt'r R'sources
MiV I tl uUAt1+Y
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority(POTW)Name: City of Raleigh
2. Control Authority Representative(s):Ryan N.Faw
3. Title(s): Industrial Pretreatment Coordinator
4. Last Inspection Date: September 26,2017 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 MM/DD/YY
N1C10 10 12191013131 1 N1C10 10 1 71 91311161 1081281181
7. Current Number Of Significant Industrial Users(SIUs)? 15
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 Sills on Schedules? 0
15. Current Number Of Categorical Industrial Users(CIUs)? 13
16. Number of CIUs m SNC? 0
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?
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.
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:None
20. Which Industries are on Compliance Schedules or Orders?For all SIUs on an None
Order-;Hasa Signed Copy of the Order been sent to the Division?
21. Are Any Penmts 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? Z 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 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:
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 :
their files,complete with supporting documents and copy of PERCS Approval Letter,and dates consistent with Program Info.
Program Element Last Submittal Last Approval Date Next Due,
Date In file? Date In file If Applicable
Headworks Analysis(HWA) 1/22/2018 ®Yes ❑ No 2/12/2018 ® Yes❑ No 12/31/2019
3/29/2018 ®Yes ❑ No 6/7/2018 ®Yes ❑ No 4/1/2023
Industrial Waste Survey(RVS) 1/27/2018 ® Yes ❑ No 2/12/2018 /1 Yes ❑ No 2/1/2023
Sewer Use Ordinance(SUO) 1/2/2013 ®Yes ❑ No 1/3/2013 ® Yes ❑ No
Enforcement Response Plan(ERP) 2/19/2009 ®Yes ❑ No 3/10/2009 ®Yes ❑ No
Long Term Monitoring Plan(LTMP) 4/1/2016 ®Yes ❑ No 6/21/2016 ®Yes ❑ No 9/1/2018
INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1.Xellia Pharmaceuticals 2.Alsco 3.GlaxoSmithKline
30. IUP Number CARD SERV GLAX
31. Does File Contain Current Permit? ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
32. Permit Expiration Date 12/31/2018 12/31/2018 12/31/2018
33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A 439.46 N/A 43 9
34. Does File Contain Permit Application Completed Within One Year Prior ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year? ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
36. a.Does the File Contain a 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
37. 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)?
38. a.Does File Contain Original Permit Review Letter from the Division? a. ®Yes ❑No 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
39. During the Most Recent Semi-Annual Period,Did the POTW Complete ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
its Sampling as Required by IUP,including flow? _
40. Does File Contain POTW Sampling Chain-Of-Custody Forms? ®Yes ❑ No ►1 Yes ❑ No ®Yes ❑ No _
41. During the Most Recent Semi-Annual Period,Did the SIU Complete its ®Yes❑No❑N/A ®Yes❑No❑N/A ®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 ®Yes❑No❑N/A ®Yes❑No❑N/A
on time?
42a For categorical IUs with Combined Wastestream Formula(CWF), does ❑Yes❑NoZN/A ❑Yes❑No®N/A ❑Yes❑NoZN/A
file include process/dilution flows as Required by IUP?
42b.For categorical IUs with Production based limits, does file include ❑Yes❑No®N/A ❑YesDNo ]N/A ❑Yes❑NoNN/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi-Annual Period,Did the POTW Identify ❑Yes❑NoNN/A ❑Yes❑NomN/A ❑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 ❑Yes❑No®N/A ❑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❑Nor4N/A a.❑Yes❑NoE1N/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❑Nor4N/A
c.If applicable,Did POTW resample within 30 days of becoming aware c.❑Yes❑No®N/A c.❑Yes❑No®N/A c.❑Yes❑No®N/A
of SIU limit violations m the POTW's sampling of the SIU?
46. During the Most Recent Semi-Annual Period,Was the SIU m SNC? ❑Yes ® No U Yes ® No ❑Yes ® No
47. During the Most Recent Semi-Annual Period,Was Enforcement Taken ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No©N/A
as Specified in the POTW's ERP (NOVs,Penalties,timing, etc.)?
48. Does the File Contain Penalty Assessment Notices? ❑Yes❑NoEIN/A ❑Yes❑No®N/A ❑Yes❑No®N/A
49. Does The File Contain Proof Of Penalty Collection? ❑Yes❑No®N/A ❑Yes❑NoNN/A1 ❑Yes❑No®N/A
50. a.Does the File Contain Any Current Enforcement Orders? a.❑Yes❑No®N/A a.❑Yes❑Nor-N/A a.❑Yes❑No®N/A
b.Is SIU in Compliance with Order? b❑Yes❑No_,N/A b❑Yes❑NoNN/A b.❑Yes❑No 2N/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑Yes ® No ❑Yes ® No ❑Yes ® No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 2

So-
FILE REVIEW COMMENTS:
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
J I I 1 1 1 1 1 1 l J ► I J
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 LINO
Industrial Inspection Comments:
OVERALL SUMIVIARY AND COMMENTS:
Comments: The program is well managed.
Requirements:None
Recommendations:None
NOD: ❑YES ®NO
NOV: ❑YES Or NO
QNCR: ❑YES ®NO
POTW Rating:
Satisfactory ®Marginal❑UnSatisfactory ❑
PCI COMPLETED BY: Cheng Zhang,Raleigh Regional Office DATE: August 28,2018
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 3