NC0060534_Compliance Evaluation Inspection_20211116

DocuSign Envelope ID: E2197017-0516-4806-A1 D6-480996494176
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTFt CAROLINA
Environmental Quality
SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED.
November 16, 2021
Tom Williams, Brevard WWTP Pretreatment Coordinator
Brevard WWTP
E-mail: [e-mail]
SUBJECT: Compliance Inspection Report
Brevard WWTP
NPDES WW Permit No. NC0060534
Transylvania County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Brevard WWTP on
11/02/2021. This inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in NPDES WW Permit No. NC0060534. The findings and comments
noted during this inspection are provided in the enclosed copy of the inspection report entitled
"Compliance Inspection Report".
Please respond in writing to this office within 30 days of your receipt of this letter regarding your plans
or measures to be taken to address the following issues:
• Submit an updated Industrial Waste Survey, this deficiency was noted in the 2020 Pretreatment
Compliance Inspection.
If you should have any questions, please do not hesitate to contact Timothy Heim with the Water
Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500 or via email at
[e-mail].
ATTACHMENTS
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Sincerely,
DocuSigned by:
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Daniel Boss, Asst. Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
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DocuSign Envelope ID: E2197017-0516-4806-A1 D6-480996494176
United States Environmental Protection Agency
EPA Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection
1 IN I 2 IL I 3 I NC0060534 111 121 21/11/02 117
Type
1811
IIIIIIIIIII
Inspector Fac Type
191 S I 2011
21IIIIII IIIIIIIIIII IIIIIII I IIIIII
P6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
671 I 70I I 711 172 I N I 73I 1 74 71
I I
I I I I I I 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Brevard WWTP
3226 Wilson Rd
Pisgah Forest NC 28768
Entry Time/Date
09:30AM 21/11/02
Permit Effective Date
17/05/01
Exit Time/Date
12:OOPM 21/11/02
Permit Expiration Date
21/09/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Emory Gaine Owen/ORC/828-883-8461/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
James N Johnston,95 W Main St Brevard NC 28712//828-884-2770/8288842358
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Pretreatment
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Timothy H Heim DWR/ARO WQ/828-296-4665/
�DocuSignegby: 11/16/2021
k.
L_082B1105A3CA418...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
..jjD�� S'g etl �bjY: 11/16/2021
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1

DocuSign Envelope ID: E2197017-0516-4806-A1 D6-480996494176
3I
NPDES yr/mo/day
NC0060534 111 121 21 /11 /02
117
Inspection Type
18 {j
(Cont.)
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Tim Heim of the Asheville Regional Office performed a Pretreatment Audit on November 2th, 2021.
Tom Williams (Brevard WWTP Lab Manager & Pretreatment Coordinator) assisted with the inspection
and with records and sampling results review. An inspection of Industrial User: (IU) Oscar Blues
Brewery (IUP # S-001-14) was performed as part of the inspection. Thomas Transue, The Director of
Brewery Operations, was also present during the IU inspection component.
The pretreatment program, associated record keeping, and the relationship with the IU were
generally in good order at the time of the inspection and compliant with permit conditions.
The following item was non -compliant with NC0060534:
Submit an updated Industrial Waste Survey, this deficiency was noted in the 2020 Pretreatment
Compliance Inspection.
See attached NC DEQ Pretreatment Compliance Audit form for details.
Page# 2

DocuSign Envelope ID: E2197017-0516-4806-A1 D6-480996494176
Permit: NC0060534
Inspection Date: 11/02/2021
Owner - Facility: Brevard WWTP
Inspection Type: Pretreatment Audit
Yes No NA NE
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DocuSign Envelope ID: E2197017-0516-4806-A1D6-480996494176
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: NC0060534
2. Control Authority Representative(s): City of Brevard
3. Title(s): Tom Williams: Pretreatment Coordinator, Laboratory Manager
4. Address of POTW:
Mailing 151 W Main Street
City Brevard, NC Zip Code 28712
Phone Number 828-883-8461 Fax Number E-Mail tom.williams(i/cityofbrevard.com
5. Audit Date 11/02/2021
6. Last Inspection Date: 03/12/2020 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ❑ Yes ® No
If No, Explain. The IWS still needs to be completed and submitted.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ❑ Yes ® No
If Yes, Explain.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number
INICI0I0I6 IO 15 13 14 I
10. Current Number of Sivnificant Industrial Users (SIUs)?
11. Number of SIUs with No IUP, or with an Expired IUP?
MM/DD/YY
I 11 I 02 I 21
1
0
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
0
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
1
14. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
0
15. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
0
16. Number of SIUs in SNC with Pretreatment Schedule?
0
17. Number of SIUs on Schedules?
0
18. Current Number of Categorical Industrial Users (CIUs)?
19. Number of CIUs in SNC?
0
0
NC DWR Pretreatment Audit Form
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DocuSign Envelope ID: E2197017-0516-4806-A1 D6-480996494176
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)
09/25/2018
a1 Yes ❑ No
01/31/2019
❑ Yes ❑ No
NA
Industrial Waste Survey (IWS)
04/11/2016
iI Yes ❑ No
01/01/2019
i1 Yes ❑ No
DUE!
Sewer Use Ordinance (SUO)
11/21/2013
/1 Yes ❑ No
12/13/2013
/1 Yes ❑ No
NA
Enforcement Response Plan (ERP)
04/07/2014
/1 Yes ❑ No
06/25/2014
/1 Yes ❑ No
NA
Long Term Monitoring Plan (LTMP)
09/25/2018
@ Yes ❑ No
01/31/2019
/1 Yes ❑ No
2023
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?
❑ Yes ® No If yes, Please list these towns and/or areas.
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑ 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.
24. Date of Last SUO Adoption by Local Council 11/21/2013
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? ® Yes ❑ No
If no, POTW must send copy within 30 days.
27. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
❑ Yes ® No If yes, Explain.
28. List Industries under a Schedule or Order and Type of Schedule or Order
NA
Resources
29. Please Rate the Followine: S=Satisfactory M=Marginal U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
@ S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
@ S ❑M ❑U
Access to Operable Sampling
Equipment
@ S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
0 S ❑M ❑U
Reference Materials
AS ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
/1S ❑M ❑U
Computer Equipment (Hardware and
Software)
/1 S ❑M ❑U
NC DWR Pretreatment Audit Form
Revised: December 2016
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DocuSign Envelope ID: E2197017-0516-4806-A1D6-480996494176
30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Surcharge on IU.
Public Perception/ Participation
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain.
33. Has any one from the public ever requested to review pretreatment program files? ❑ Yes ® No
If yes, Explain procedure. If no, how would the request be addressed?
34. Has any industry ever requested that certain information remain confidential from the public? ❑ 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?
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
37. Were all industries in SNC published in the last notice? ❑ Yes ❑ No ® (NA)
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? Building Department. Public Works, City Council
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?) The industry is evaluated for applicability, and DEQ pretreatment experts are consulted if appropriate.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
▪ Yes No If Yes, How many are there?
Please list each site and how it is permitted, if applicable.
41. Does the POTW accept waste by (mark if applicable) ® Truck ❑Dedicated Pipe ❑ NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) Dedicated discharge point, manifest, supervised unloading.
43. How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits ® Historical Industry Need ® By Surcharge ❑ Categorical Limits ❑ Other
Explain Other:
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ❑ Yes ® No
If yes, what parameters are over allocated? NA
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
NA
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter 50%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain. NA
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)
Pollutants of concerns applicable to the brewing industry.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain
NC DWR Pretreatment Audit Form
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DocuSign Envelope ID: E2197017-0516-4806-A1 D6-480996494176
Annual monitoring as required.
Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No
If yes, which industries? What was (will be) the outcome of the adjudication? NA
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. Monitor limits and reporting requirements.
52. Does the POTW use the Division's model inspection form or equivalent? ® 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? ® Yes ❑ No
If no, Explain. Updated Nov 2021.
54. What criteria are used to determine if a slug/spill control plan is needed?
Potential for release an impact of released materials.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Evaluated against potential impact.
56. How does the POTW decide where the sample point for an SIU should be located?
IU effluent at metering point prior to introduction to CS.
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: ® Yes ❑ No SIU: ® Yes ❑ No If yes, Explain. Laboratory SOPs & BPs.
58. Who performs sample analysis for the POTW for Metals ETS Labs
Conventional Parameters ETS Labs
Organics ETS Labs
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
ETS Laboratory SOPs & BPs.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES El NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES El NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ❑ YES ® NO Division Inspector, verify yourself!
60e. If NO to any above, list violations _LTMP Needs to be updated.
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA) ? ❑ Yes ® No
If no, who completes your HWA? Byers Environmental Phone [phone]
62. Do you have plans to revise your HWA in the near future? ® Yes ❑ No
If yes, what is the reason for the revision? (mark all that apply) ❑Increased average flow
❑NPDES limits change
EMore LTMP data available ❑Resolve over allocation ®5 year expiration ❑Other
Explain.
63. In general, what is the most limiting criteria of your HWA? ❑Inhibition ® Pass Through ❑Sludge Quality
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ® No
Explain.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
NC DWR Pretreatment Audit Form
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DocuSign Envelope ID: E2197017-0516-4806-A1 D6-480996494176
No changes planned.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

DocuSign Envelope ID: E2197017-0516-4806-A1 D6-480996494176
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Oskar Blues Brewery
2. NA
3. NA
67. IUP Number
S-001-14
68. Does File Contain Current Permit?
0 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
69. Permit Expiration Date
8/31/2021
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
NA
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. ►Yes •No
b. •Yes •No
a. •Yes •No
b. •Yes ■No
a. •Yes •No
b. •Yes •No
Certification, Does File Contain a Toxic
(TOMP)?
❑Yes❑NoON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
74. For 40 CFR 413 and 433 TTO
Organic Management Plan
75. a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. ►Yes •No
b.❑Yes❑No❑N/A
a. •Yes •No
b.❑Yes❑No❑N/A
a. •Yes •No
b.❑Yes❑No❑N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
Sampling as Required by IUP, including Flow?
0 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
Al Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
Sampling as Required by IUP, including Flow?
®Yes❑No❑N/A
❑ Yes ❑No❑N/A
❑Yes❑No❑N/A
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
time?
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑NoON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Limits Non -Compliance from Both POTW and SIU Sampling?
i1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting Non -Compliance from SIU Sampling?
❑Yes❑NoON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
83. a. Was 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 and obtain results within 30 days of
becoming aware of SIU limit violations in the POTW's sampling of SIU?
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
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑ Yes 1 No
❑ Yes ❑ No
❑ Yes ❑ No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
❑Yes❑NoON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
86. Does File Contain Penalty Assessment Notices?
❑Yes❑NoNN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑NoON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
88. a. Does File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
❑ Yes A No
❑ Yes ❑ No
❑ Yes ❑ No
FILE REVIEW COMMENTS: NA
NC DWR Pretreatment Audit Form Revised: December 2016
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DocuSign Envelope ID: E2197017-0516-4806-A1 D6-480996494176
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INICIO 10 16 Io 15 13 14 I I11 IO2I21 I
1. Industry Inspected: Oskar Blues Brewery
2. Industry Address: 342 Mountain Industries Drive, Brevard, NC 28712
3. Type of Industry/Product: Craft Beer
4. Industry Contact: Thomas Transue Title: Dir. of Operations Phone: [phone] Fax: [phone]
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 ❑ No
Industrial Inspection Comments:
The brewery staff demonstrated full and thorough knowledge of their production process and the need to continuously
communicate with the WWTP. The Spill Control Plan is adequate and up to date.
Audit SUMMARY AND COMMENTS:
Audit Comments:
Requirements: No additional requirements.
Recommendations: Continued to maintain good communication between the brewery and Brevard Pretreatment Coordinator.
NOD: ® Yes ❑ No : Complete the IWS ASAP. This deficiency was noted in the 2020 PCI.
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory
Audit COMPLETED BY: Tim Heim
Marginal ❑ Unsatisfactory ❑
�DocuSignatl by:
Asheville Regional Office
DATE: 11/16/2021
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 7