There is no known OCD obsession or compulsion that is impervious to CBT, ERP, medications, or surgery.
However, there are individuals who have not gotten much assistance from any of these forms of treatment, yet there is no clear theme of obsessions or compulsions that goes across the board for these individuals.
OCD treatment is effective and helps most people who seek it out if they are willing to stick to the treatment. However, there will be individuals that will struggle with therapy.
Therefore, instead of looking for a type of OCD that may be impervious to treatment, it may be better to search for personality traits that make accepting or responding to treatment more difficult.
Or, brain scanning and imaging may, in the future, lead us to further understandings of why certain individuals have difficulty with treatment.