NC0024911_Inspection_20190625

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NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resources
ENVIRONMENTAL QUALITY
Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: MSD
2. Control Authority Representative(s): Shannon Bergeron
3. Title(s): Pretreatment Coordinator
4. Address of POTW:
Mailing 2028 Riverside Drive
City Asheville Zip Code 28804
Phone Number 828-225-8230 Fax Number E-Mail sbergeron(W,)msdbc.org
5. Audit Date 6/10/2019
6. Last Inspection Date: 7/25/2018 Inspection Type: X PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? X Yes ❑ No
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? X Yes ❑ No
If Yes, Explain. Alum sludge NOD (NOD-2018-PC-0326, December 2018 Bypass NOV/CPA (NOV-2019-PC-
0083/PC-2019-0019), February 2019 Bypass NOV/CPA(NOV-2019-PC-0251/PC-2019-0034), DMR NOV (NOV-
2019-LV-0238, NOV-2019-MV-0069). Note: WWTP is underway with major construction projects; Permit has
lengthy Ammonia Compliance Schedule. These noted NOD/NOV's are not directly related to Pretreatment
Permits.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes X No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No x NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number MM/DD/YY
INIC101012 I4 19 I1 I1 I I6 I10I19�
10. Current Number of Significant.Industrial Users (SIUs)?
.................................................................
11. Number of SIUs with No IUP, or with an Expired IUP?
................................................................................................................................................................................................................................................................................
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
................................................................................................................................................................................................................................................................................
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
................................................................................................................................................................................................................................................................................
14. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
................................................................................................................................................................................................................................................................................
15. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
................................................................................................................................................................................................................................................................................
16. Number of SIUs in SNC with Pretreatment Schedule?
................................................................................................................................................................................................................................................................................
17. Number of SIUs on Schedules? Arcadia and Jacob Holmes.
18. Current Number of
19. Number of CIUs in SNC?
Industrial Users (CIUs)?
22
0
0
0
0
0
0
2
16
0
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20. 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)
3/26/19
x Yes ❑ No
pending
❑ Yes ❑ No
Industrial Waste Survey (IWS)
12/1/14
x Yes ❑ No
2/20/15
x Yes ❑ No
Sewer Use Ordinance (SUO)
11/28/11
x Yes ❑ No
12/12/11
x Yes ❑ No
Enforcement Response Plan (ERP)
10/6/04
x Yes ❑ No
5/2/05
x Yes ❑ No
Long Term Monitoring Plan (LTMP)
4/30/19
x Yes ❑ No
pending
❑ Yes ❑ No
Legal Authority (Sewer Use Ordinance-SUO)
21. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
X Yes ❑ No If yes, Please list these towns and/or areas. Cane Crk (Agreement in place; MSD does IWS/Pretreat).
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? x Yes ❑ No ❑ NA
A copy, if not already submitted, should be sent to Division.
23. If yes to #21, Have you had any trouble working with these towns or districts? ❑ Yes ❑ No ❑ NA
If yes, Explain. Past issues with Cane Crk not notifying MSD of new industry, but has improved recently.
24. Date of Last SUO Adoption by Local Council 5/16/2012
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes x No
If yes, Explain. MSD plans to update and strengthen Enf. and Rules on Breweries and FOG.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? ❑ Yes x No
If no, POTW must send copy within 30 days. MSD will put on website and send Industries Link.
27. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
❑ Yes x No If yes, Explain. MSD plans to update in 2020.
28. List Industries under a Schedule or Order and Type of Schedule or Order
Arcadia; Administrative Order Exp. 12/2019. Jacob Holmes; Consent Agreement Exp. 7/2019.
Resources
29. Please Rate the Following: S=Satisfactory M=Mareinal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
1 FT, 2 PT. Large program; another PT position may be
POTW's Pretreatment Program
❑S X M ❑U
warranted, especially with Asheville growth, Brewery, Eateries.
Access to POTW Vehicles for
Sampling, Inspections, and
X S ❑M ❑U
Emergencies
Access to Operable Sampling
6 sampling devices.
Equipment
X S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
X S ❑M ❑U
Reference Materials
X S Elm ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
X S ❑M ❑U
Computer Equipment (Hardware and
Software)
X S ❑M ❑U
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30. Does the POTW have an adequate data management system to run the pretreatment program? x Yes ❑ No
Explain Yes or No. Microsoft, Access
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
IU billing, surcharges, septic haulers; considering additional fee for restaurants.
Public Perception/ Participation
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes x No If yes, Explain. Breweries have anaerobic treatment, future NH3 limits could impact this industry.
33. Has any one from the public ever requested to review pretreatment program files? x Yes ❑ No
If yes, Explain procedure. If no, how would the request be addressed? Breweries; MSD notified them of the review.
34. Has any industry ever requested that certain information remain confidential from the public? x 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? SUO listed qualifying. Locked files.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? x Yes ❑ No
36. Is the public notified about changes in the SUO or Local Limits? x Yes ❑ No Public Notices.
37. Were all industries in SNC published in the last notice? ❑ Yes ❑ No x N/A
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? NCMR, Chamber Commerce, Planning/Development.
39. 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?) SIU reports changes, MSD inspects, require Long Form, IWS triggers.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
xYes ❑No If Yes, How many are there? 6.
Please list each site and how it is permitted, if applicable. IU. Balcrank, Wilsonart, Square D, Ticar, Chemtronic,
Charrah, GHIA.
41. Does the POTW accept waste by (mark if applicable) x Truck x Dedicated Pipe ❑ NA Septic, Leachate. GW
Remediation, GHIA P&H.
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) Designated points, MH. Samples obtained by industry and MSD.
43. How does the POTW allocate its loading to industries? Mark all that apply
X Uniform Limits x Historical Industry Need ❑ By Surcharge x Categorical Limits ❑ Other
Explain Other:
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? x Yes ❑ No
If yes, what parameters are over allocated? Silver (low stream standard), Pending; Vivien will address in letter.
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
Detection level review historical data.
46. Does the POTW keep pollutant loading in reserve for future growth / safety? X Yes ❑ No
If yes, what percentage of each parameter 10%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes x 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)
Allocation table, limits in SUO.
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49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Risk level.
Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes x 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. Emails-Reporting. Database, Checklist, Billing; MSD judges
compliance w/in 30 days.
52. Does the POTW use the Division's model inspection form or equivalent? x Yes ❑ No
If no, does the POTW form include all Division data? ❑ Yes ❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? x Yes ❑ No
If no, Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
Onsite chemicals, SDS, floor drains.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
DWR website for elements to include.
56. How does the POTW decide where the sample point for an SILT should be located?
No dilution, below treatment units.
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: x Yes ❑ No SIU: x Yes ❑ No If yes, Explain. Hands on training by MSD.
58. Who performs sample analysis for the POTW for Metals PACE
Conventional Parameters PACE
Organics PACE
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
PACE COC
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? X YES ❑ NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? X YES ❑ NO Vivien will note in letter.
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? x YES ❑ NO Is Table Adequate? x YES ❑ NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? x YES ❑ NO Division Inspector, verify yourself.
60e. If NO to any above, list violations
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES x NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA) ? x Yes ❑ No
If no, who completes your HWA? Phone ( ) --
62. Do you have plans to revise your HWA in the near future? ❑ Yes x No
If yes, what is the reason for the revision? (mark all that apply) ❑Increased average flow ❑NPDES limits change
❑More LTMP data available ❑Resolve over allocation x 5 year expiration ❑Other
Explain.
63. In general, what is the most limiting criteria of your HWA? X Inhibition ❑ Pass Through ❑Sludge Quality BOD, Ag, Air
Permit.
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ❑ No
Explain. Planned and ongoing WWTP Improvements.
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Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
Significant improvements to WWTP underway; Permit NH3 Compliance Schedule.
File review was not performed due to time restraints. One will be performed at a later date.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I N I C 1 0 10 12 14 19 11 11 I 1061101191
1. Industry Inspected: New Belgium Brewing Compan
2. Industry Address: 91 Craven St
3. Type of Industry/Product: Brewery
4. Industry Contact: Nick Ampe Title: EHS Phone: [phone] Fax:
5. Does the POTW Use the Division Model Inspection Form or Equivalent? x Yes ❑ No MSD's more detailed.
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview x Yes ❑ No
B. Plant Tour x Yes ❑ No
C. Pretreatment Tour x Yes ❑ No
D. Sampling Review x Yes ❑ No
E. Exit Interview x Yes ❑ No
Industrial Inspection Comments:
Thorough inspection conducted.
Audit SUMMARY AND COMMENTS:
Audit Comments: MSD's Pretreatment program appears well managed. For a small tourist destination City, they have several
Metal Industries, many breweries (76) and eateries to manage (1300). With the anticipated growth in the area, the noted
complexities and future NH3, additional staffing may be needed to maintain such a well -managed program.
Shannon Bergeron and Chad Ledford met with Linda Wiggs and Vivien Zhong.
Requirements:
Recommendations:
NOD: ❑ Yes x No
NOV: ❑ Yes x No
QNCR: ❑ Yes x No
POTW Rating:
EW)
Satisfactory x Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Linda Wiggs (ARO), Vivien Zhong (PERCS) DATE: June 10, 2019
PERCS, and Asheville Regional Office
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