NC0021229_NOD2022PC0138 & Pretreatment Compliance Audit Inspection Report_20220907

SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED.

September 7, 2022

Rick Hensley
Town of Old Fort
Email: [e-mail]

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2022-PC-0138
Permit No. NC0021229
Old Fort WWTP
McDowell County

Dear Permittee:

The North Carolina Division of Water Resources conducted a Pretreatment Compliance Audit inspection of the Old
Fort WWTP on August 23, 2022. This inspection was conducted to verify that the facility is operating in
compliance with the conditions and limitations specified in NPDES WW Permit No. NC0021229. The purpose of the
audit is to determine the effectiveness of the Pretreatment Program by an in-depth review of the files, including the
industrial monitoring data, appropriate data management, and adherence to the Enforcement Response Plan.
Please see the enclosed Pretreatment Compliance Audit Inspection form for more detailed information about the
inspection. The Pretreatment Program was given a marginal rating.

The Pretreatment Compliance Audit Inspection was conducted by Division of Water Resources staff from the
Asheville Regional Office. The following deficiencies were noted during the inspection:
Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________ Pretreatment An inspection was not conducted at Hillman Beer in 2021.
_________________________________________________________________________________________________________________________________________________________________________
Pretreatment A Notice of Non-Compliance or Notice of Violation was not issued to Hillman Beer for the
monthly average BOD limit exceedance for August 2021. _________________________________________________________________________________________________________________________________________________________________________

DocuSign Envelope ID: 53C60B93-1488-4273-A771-6BFA6DD932CB

Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. To prevent further action, carefully review these deficiencies and address the causes of
non-compliance to prevent the recurrence of similar situations.
If you should have any questions, please do not hesitate to contact Lauren Armeni with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4667.

Sincerely,

Daniel Boss, Assistant Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Reports

Ec: Laserfiche
Josh Cagle (ORC/Pretreatment Coordinator)
DocuSign Envelope ID: 53C60B93-1488-4273-A771-6BFA6DD932CB
EPA
United States Environmental Protection Agency
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 Type Inspector Fac Type
1 N 52 NC0021229 22/08/23 G S31112171819 20
21 66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
N67707172 73 74 75 80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Old Fort WWTP
Catawba Ave US Hwy 70
Old Fort NC 28762
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
09:00AM 22/08/23 20/10/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Joshua Kenneth Cagle/ORC//
Other Facility Data
12:00PM 22/08/23 25/01/31
Name, Address of Responsible Official/Title/Phone and Fax Number
Asley Wooten,60 E Court St Marion NC 28752//828-652-7121/Contacted
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
Lauren E Armeni DWR/ARO WQ/828-296-4500/
Stephanie A Williams DWR/ARO WQ/828-296-4500/
Mikal Willmer DWR/Division of Water Quality/828-296-4686/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#1
DocuSign Envelope ID: 53C60B93-1488-4273-A771-6BFA6DD932CB
9/6/2022
9/6/2022
9/7/2022
9/7/2022
NPDES yr/mo/day
22/08/23
Inspection Type
G3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Lauren Armeni, Mikal Willmer, and Stephanie Williams, with the Asheville Regional Office, conducted
a Pretreatment Compliance Audit Inspection (PCA) of the Town of Old Fort's Pretreatment Program
on August 23, 2022. Mr. Josh Cagle (Pretreatment Coordinator/ORC) was present during the
inspection.
The Town of Old Fort's Pretreatment Program was approved on March 23, 2020 and consists of two
Significant Industrial Users (SIUs) - Hillman Beer and Whaley Farm Brewery. The Town's previous
Pretreatment Program was made inactive in 2011. Mr. Cagle started with the Town of Old Fort in
September 2021. For the month of August 2021, Hillman exceeded its monthly average BOD limit,
and a Notice of Violation (NOV) was not issued. This was the only exceedance for 2021. For the first
semi-annual sampling period of 2022, Hillman exceeded their monthly average BOD and TSS limits
for April 2022. Mr. Cagle followed the ERP and issued an NOV to Hillman Beer. Mr. Greig Hillman
(owner of Hillman Beer) responded to the NOV, indicating that the catch basin that was built into the
brewery drain system to catch the solids was not being cleaned out enough, which ultimately caused
the exceedances. Moving forward, this basin will be cleaned at least weekly.
The Industrial User Permit was issued to Whaley Farm Brewery on June 1, 2021, but the brewery did
not start production until August 2022. Prior to starting production, Mr. Cagle inspected the brewery.
The annual inspection was not conducted for Hillman Beer in 2021. Mr. Cagle is aware that each SIU
needs to be inspected yearly, and during the audit he conducted the inspection at Hillman for 2022.
The Headworks Analysis (HWA) was submitted in 2020, but Mr. Cagle and Mr. Keyes McGee (DEQ
NPDES Pretreatment Coordinator) cannot find it. Mr. Cagle is attending the Pretreatment Conference
this month and will work on the HWA with Mr. McGee.
Currently, the Short Term Monitoring Plan (STMP) data is not maintained on a table. Ms. Armeni
discussed the spreadsheet template we have and will send it to Mr. Cagle.
Overall, paperwork for the Pretreatment Program is lacking organization; however, it is understood
that Mr. Cagle is new to the program and is doing his best to learn it and is seeking out resources to
further his knowledge.
The following deficiencies were noted during the inspection:
1. An inspection was not conducted at Hillman Beer in 2021.
2. A Notice of Non-Compliance or Notice of Violation was not issued to Hillman Beer for the monthly
average BOD limit exceedance for August 2021.
NC0021229 17 (Cont.)
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NC DWR Pretreatment Audit Form Revised: December 2016 Page 1

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT

Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Old Fort WWTP
2. Control Authority Representative(s): Josh Cagle
3. Title(s): Pretreatment Coordinator/ORC
4. Address of POTW:
Mailing 1174 East Main Street
City Old Fort Zip Code 28762
Phone Number 828-655-6755 Fax Number E-Mail [e-mail]
5. Audit Date 08/23/22
6. Last Inspection Date: 09/22/10 Inspection Type: PCI Audit
Note: Old Fort’s previous Pretreatment Program was made inactive in 2011. This PCA inspection was the first for the new
Pretreatment Program approved in March 2020.
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? Yes No
If No, Explain.

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 MM/DD/YY
N C 0 0 2 1 2 2 9 08 23 22

10. Current Number of Significant Industrial Users (SIUs)? 2
11. Number of SIUs with No IUP, or with an Expired IUP ? 0
12. Number of SIUs Not Inspected by POTW in Last Calendar Year? 1
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)? 0
19. Number of CIUs in SNC? 0

* - Whaley Farm Brewery was permitted in June 2021 but they were not operating until August 2022.

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NC DWR Pretreatment Audit Form Revised: December 2016 Page 2
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) 03/13/20 Yes No 03/23/20 Yes No 06/01/21
Industrial Waste Survey (IWS) 03/20/20 Yes No 03/23/20 Yes No 06/01/24
Sewer Use Ordinance (SUO) 11/15/19 Yes No 04/20/20 Yes No N/A
Enforcement Response Plan (ERP) 03/16/20 Yes No 03/23/20 Yes No N/A
Short Term Monitoring Plan (STMP) 03/16/20 Yes No 03/23/20 Yes No N/A

Note: Ms. Armeni spoke with Mr. Keyes McGee (DEQ Municipal Unit, Pretreatment Coordinator) on August 29, 2022, and was
informed that he could not find any of the HWA files that had been submitted in 2020. The HWA was submitted prior to Mr. Cagle
starting at the Town of Old Fort, and Mr. Cagle could also not find the files. Mr. Keyes is going to work with Mr. Cagle on a new
HWA at the Pretreatment Conference in September 2022. Mr. Keyes could also not find approval letters for the IWS, SUO, ERP,
and STMP, but was able to send Ms. Armeni the approved documents.

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 04/20/20

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. (Mr. Cagle confirmed that the ERP was hand delivered to the SIUs on August 31,
2022.)
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
N/A

Resources

29. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
Rating Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW’s Pretreatment Program

S M U
Another full-time person could be utilized at the WWTP.
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

S M U

Reference Materials

S M U

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NC DWR Pretreatment Audit Form Revised: December 2016 Page 3
Staff Training (i.e. Annual and
Regional Workshops, Etc.)

S M U

Computer Equipment (Hardware and
Software)

S M U

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 indu stries? Explain.
The POTW charges industries a monthly pretreatment fee and the POTW is paid for sampling.

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 anyone from the public ever requested to review pretreatment program files? Yes No
If yes, Explain procedure. If no, how would the request be addressed? The POTW would inquire with the DEQ.

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 confide ntial status, as well as procedure for keeping files confidential from
public. If no, how would the request be addressed? The POTW would inquire with the DEQ.

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? The POTW informed the current SIUs to contact them
if something changes with the industry processes. New industries contact Town Hall to fill out an application.
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 POTW looks at flow from the industry and what they’re producing, as well as provides the IWS for
them to fill out.

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) N/A

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: Mr. Cagle was not sure how the previous ORC allocated its loading to industries.

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? Note: Mr. Cagle and Mr. Keyes could not find the most recent HWA that
was submitted in 2020; therefore Ms. Armeni could not review the allocation tables.

45. If yes to #44, What is being done to address the over allocations? (short -term IUPs, HWA to be revised, pollutant study, etc.)

46. Does the POTW keep pollutant loading in reserve for future growth / safety? Yes No
If yes, what percentage of each parameter % Note: This question couldn’t be evaluated, see note in #44.
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NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

47. Has the POTW experienced any difficulty in allocation? (For example: adjudication by an industry) Yes No
If yes, Explain. Note: This question couldn’t be evaluated, see note in #44.

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)
The POTW decides based on the IWS and historical industry knowledge. The two SIUs are breweries, and breweries
generally have high BOD/TSS.

49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
The monitoring frequency is based on the type of industry and the potential for the industry to negatively impact the
POTW.

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?

51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporti ng
requirements, and permit conditions, as well as for SNC. The POTW judges compliance by sampling at industries and looks at
the ERP to determine violations or what needs to be sent out.

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. Hillman Brewing was not inspected in 2021 and Whaley Farm Brewery was not in operation in 2021.

54. What criteria are used to determine if a slug/spill control plan is needed?
Whether or not the product from the industry will negatively impact the WWTP.

55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Currently, the POTW doesn’t have criteria to determine if a slug /spill control plan is adequate; however, Ms. Armeni will
be sending Mr. Cagle and the SIUs an example slug/spill control plan.

56. How does the POTW decide where the sample point for an SIU should be located?
The sample point is the last point before it mixes with domestic wastewater.

57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each ti me?
(example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: Yes No SIU: Yes No If yes, Explain. The POTW samples for the SIUs. The POTW sets
up the composite sampler with ice, lets it sit for 24 hours and then collects samples.

58. Who performs sample analysis for the POTW for
Metals GEL Laboratories – Low level mercury; Pace – Other metals
Conventional Parameters ETS – Hillman, Watertech - Whaley
Organics N/A

59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
After samples are collected, the CoC is filled out and then the lab signs the CoC once they pick up the sample or the sample
is dropped off to the lab. Samples are dropped off to ETS and a Watertech courier picks samples up.

Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)

60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? YES NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? YES 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 _____________________________________________________________________
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? YES NO
If yes, which ones? Eliminated: Added:________________________________

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NC DWR Pretreatment Audit Form Revised: December 2016 Page 5
61. Do you complete your own headworks analysis (HWA) ? Yes No
If no, who completes your HWA? 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
More STMP data available Resolve over allocation 5 year expiration Other
Explain. The STMP needs to be revised to include Whaley Farm Brewery.

63. In general, what is the most limiting criteria of your HWA? Inhibition Pass Through Sludge Quality
This will be determined once the new HWA is completed. Mr. Cagle will be working on the HWA with Mr. Keyes.

64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? Yes No
Explain. See explanation for #63.

Summary

65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No.
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NC DWR Pretreatment Audit Form Revised: December 2016 Page 6
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name 1. Hillman Beer 2. Whaley Farm Brewery 3.
67. IUP Number F06 F07
68. Does File Contain Current Permit? Yes No Yes No Yes No
69. Permit Expiration Date 03/22/25 05/31/26
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A N/A N/A
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
Yes No Yes No Yes No
72. Does File Contain Inspection Completed Within Last Calendar Year? 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
74. For 40 CFR 413 and 433 TTO Certification, D oes File Contain a Toxic
Organic Management Plan (TOMP)?
Yes No N/A Yes No N/A Yes No N/A
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?
Yes No Yes No Yes No
77. Does File Contain POTW Sampling Chain -Of-Custody Forms? 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 No N/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?
Yes No N/A Yes No N/A Yes No
82. During Most Recent Semi-Annual Period, Did POTW Identify All
Reporting Non-Compliance from SIU Sampling?
Yes No N/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 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 No N/A Yes No N/A Yes No N/A
86. Does File Contain Penalty Assessment Notices? Yes No N/A Yes No N/A Yes No N/A
87. Does File Contain Proof Of Penalty Collection? Yes No N/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 No Yes No Yes No
FILE REVIEW COMMENTS:
Currently, the POTW samples for the SIUs. Since POTW samples the SIUs, if a violation occurs the POTW knows about it before
the SIU. Mr. Cagle can discuss amending the IUPs to include sampling for the industries with Mr. Keyes considering there are
limited staff at the POTW. An inspection was not conducted for Whaley Farm Brewery in 2021 because they were not in
operation.

The STMP needs to be revised because the POTW no longer has a sludge permit and Whaley Farm Brewery needs to be added.

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NC DWR Pretreatment Audit Form Revised: December 2016 Page 7
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
N C 0 0 2 1 2

2

9 08 23 22

1. Industry Inspected: Hillman Brewing
2. Industry Address: 78 Catawba Avenue, Old Fort, NC 28762
3. Type of Industry/Product: Brewery
4. Industry Contact: Greig Hillman Title: Owner Phone: [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 No

Industrial Inspection Comments:

A spill kit and Slug/Spill Control Plan was recommended because a sanitary sewer drain is in the brewing area and there is no
secondary containment around the brewing tanks.

Audit SUMMARY AND COMMENTS:
Audit Comments: Mr. Cagle is still learning the Pretreatment Program and all the documents associated with it, so it is
understandable that he had some difficulty with answering the audit questions and locating some documents. He has been doing
a good job of completing all the required sampling and following the ERP in 2022. He is attending the Pretreatment Conference
in September.
Requirements: At the time of the inspection, Hillman Beer did not have a copy of the Enforcement Response Plan (ERP). Mr.
Cagle took a copy of the ERP to Hillman Beer and Whaley Farm Brewery on August 31, 2022.
Recommendations: It is recommended to lock the autosampler when the POTW is sampling the SIUs. It is also recommended to
establish a written protocol for assessi ng criteria for SIUs when requiring a Slug/Spill Control Plan and determining if it is
adequate.

NOD: Yes No
NOV: Yes No
QNCR: Yes No

POTW Rating:
Satisfactory Marginal Unsatisfactory

Audit COMPLETED BY: Lauren Armeni DATE: 08/23/22
PERCS and Asheville Regional Office
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