NC0024911_PCI_20230223

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

February 23, 2023

Thomas Hartye P.E.
Metropolitan Sewerage District (MSD)
E-mail: [e-mail]

SUBJECT: Pretreatment Compliance Inspection Report
French Broad River WRF
NPDES WW Permit No. NC0024911
Buncombe County

Dear Mr. Haryte:

The North Carolina Division of Water Resources conducted an inspection of the French Broad River WRF
Pretreatment Program on 02/21/2023 and 02/23/2023. This inspection was conducted to verify that the
facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No.
NC0024911. The findings and comments noted during this inspection are provided in the enclosed copy of the
inspection report entitled "Compliance Inspection Report".

If you should have any questions, please do not hesitate to contact me with the Water
Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500 or via email at
[e-mail].

Sincerely,

Tim Heim PE, Environmental Engineer
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS

Ec: LF, Bart Farmer, Shannon Bergeron, Chad Ledford
DocuSign Envelope ID: CFBB6E9B-4617-4BEC-98F6-41A3863FECE2
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 NC0024911 23/02/23 P 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)
French Broad River WRF
NC Hwy 251
Asheville NC 28814
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
08:30AM 23/02/23 18/10/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Bart T Farmer/ORC/828-225-8224/
Other Facility Data
01:00PM 23/02/23 22/12/31
Name, Address of Responsible Official/Title/Phone and Fax Number
Thomas E Hartye,2028 Riverside Dr Asheville NC 288043054/General
Manager/828-225-8399/
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
Timothy H Heim DWR/ARO WQ/828-296-4665/
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: CFBB6E9B-4617-4BEC-98F6-41A3863FECE2
2/23/2023
2/23/2023
NPDES yr/mo/day
23/02/23
Inspection Type
P3111218
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 Compliance Inspection (PCI) on
February 21st & 23rd, 2023. Chad Ledford (MSD Pretreatment), and Leslie Frady (Milkco EH&S)
assisted with the inspection and with records and sampling results review.
The pretreatment program, associated record keeping, and the relationship with the IUs were in good
order at the time of the inspection and compliant with permit conditions.
DEQ ARO staff observed pretreatment inspection and sampling of an Industrial User: (IU) in the
program, Milkco Inc. (IUP # S-036).
See attached NC DEQ Pretreatment Compliance Inspection form for details.
NC0024911 17 (Cont.)
Page#2
DocuSign Envelope ID: CFBB6E9B-4617-4BEC-98F6-41A3863FECE2
Permit:NC0024911
Inspection Date:02/23/2023
Owner - Facility:
Inspection Type:
French Broad River WRF
Pretreatment Compliance
Yes No NA NE
Page#3
DocuSign Envelope ID: CFBB6E9B-4617-4BEC-98F6-41A3863FECE2
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT

BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: MSD Buncombe County
2. Control Authority Representative(s): Shannon Bergeron & Chad Ledford
3. Title(s): Pretreatment Coordinator & Pretreatment Supervisor
4. Last Inspection Date: 4/13/2022 Inspection Type (Check One): X PCI Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? X YES NO
6. Is POTW under an Order That Includes Pretreatment Conditions? YES X NO
Order Type, Number, Parameters: ____________________________ Are Milestone Dates Being Met? YES NO X NA

ICIS CODING
Main Program Permit Number MM/DD/YY
| N | C | 0 | 0 | 2 | 4 | 9 | 1 | 1 | | 02 | 21 | 23 |

7. Current Number Of Significant Industrial Users (SIUs)? 19
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 SIUs on Schedules? 0
15. Current Number Of Categorical Industrial Users (CIUs)? 11
16. Number of CIUs in SNC? 0

POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations?
If Yes, What are the Parameters and How are these Problems Being Addressed?
YES NO
No exceedances in past year.

18. Since the Last PCI, has the POTW had any Problems Related to an Industrial
Discharge (Interference, Pass-Through, Blockage, Citizens’ Complaints, Increased
Sludge Production, Etc.)?
If Yes, How are these Problems Being Addressed?
YES X NO
Note: Milkco Inc. has caused
discoloration of influent. PT
Program working closely with
industry.

19. Which Industries have been in SNC for Limits or Reporting during
either of the Last 2 Semi-Annual Periods? Not Been Published for
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
SNC for Limits: NA
SNC for Reporting: NA
Not Published: NA

20. Which Industries are on Compliance Schedules or Orders? For all SIUs on an
Order, Has a Signed Copy of the Order been sent to the Division?

None

21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
YES X NO

LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? X YES NO
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? X YES NO (Se has been added).
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? X YES NO Is Table Adequate? X YES NO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? X YES NO 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? X YES NO
If yes, which ones? Eliminated: Total Phenols, Tin (Sn) (Stet ‘22) Added:___None___________________

DocuSign Envelope ID: CFBB6E9B-4617-4BEC-98F6-41A3863FECE2
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2
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
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA) 3-27-2019 X Yes No 7-10-2019 X Yes No 4-1-2024
Industrial Waste Survey (IWS) 10-31-2019 X Yes No 4-2-2020 X Yes No 11-01-2024
Sewer Use Ordinance (SUO) 4-12-2022 X Yes No Pending NA No
Enforcement Response Plan (ERP) 6-30-2020 X Yes No 9-22-2020 X Yes No
Long Term Monitoring Plan (LTMP) 8-18-2020 X Yes No Pending X Yes No
________________________________________________________________________________________________________________
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. Milkco Inc. (Inspected) 2. 3.
30. IUP Number S-036
31. Does File Contain Current Permit? X Yes No
32. Permit Expiration Date 12-31-2026
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A NA
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
Yes No

35. Does File Contain an Inspection Completed Within Last Calendar Year? X Yes No
36. a. Does the File Contain a Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. X Yes No
b. Yes No

37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
NA
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. xYes No
b.Yes No N/A

39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
X Yes No

40. Does File Contain POTW Sampling Chain -Of-Custody Forms? X Yes No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
xYes No N/A
41b. During the Most Recent Semi-Annual Period, Did SIU submit all reports
on time?
xYes No N/A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
NA
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
NA
43a. During the Most Recent Semi-Annual Period, Did the POTW Identify
All Limits Non-Compliance from Both POTW and SIU Sampling?
Yes No
NA

43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non-Compliance from SIU Sampling?
X Yes No
44. a. Was the 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 within 30 days of becoming aware
of SIU limit violations in the POTW’s sampling of the SIU?
a.Yes NoxN/A

b.Yes No N/A

c.Yes No N/A

46. During the Most Recent Semi -Annual Period, Was the SIU in SNC? Yes X No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
NA
48. Does the File Contain Penalty Assessment Notices? Yes: Prev. Periods
49. Does The File Contain Proof Of Penalty Collection? Yes: Prev. Periods
50. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
No: NA
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
Yes X No

DocuSign Envelope ID: CFBB6E9B-4617-4BEC-98F6-41A3863FECE2
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

FILE REVIEW COMMENTS: File and record keeping was extremely thorough and well organized.

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
| N | C | 0 | 0 | 2 | 4 | 9 | 1 | 1 | | 2 | 21 | 2023 |

1. Industry Inspected:______Milkco Inc._____________________________________
2. Industry Address:___220 Deaverville Road___________________________________________________
3. Type of Industry/Product:__Milk and associated liquid dairy products_______________________________________
4. Industry Contact:_Leslie Frady_____________________________Title: Environmental & Safety Manager____________
Phone:[e-mail]____________________
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 inspection included: T. Heim (ARO), Chad Ledford (MSD), and Leslie Frady (Milkco, Inc.).

OVERALL SUMMARY AND COMMENTS:
Comments:_MSD continues to set the standard for Pretreatment Programs in the Region. Mr. Ledford’s IU inspection and records
review were thorough and professional.
______________________________________________________________________________________________________________
Requirements: _None_____________________________________________________________________________________________
__________________________________________________________________________________________________________
Recommendations: _It is advised that the Pretreatment Program continue to consider additional staff resources for the Pretreatment
Program as needs dictate. The sewershed served by this program includes an unusually high density of fermented beverage
manufacturers per capita. This may necessitate additional technical and/or administrative staff to support the program.
NOD: YES NO
NOV: YES NO
QNCR: YES NO
POTW Rating:
Satisfactory X Marginal UnSatisfactory
PCI COMPLETED BY: Tim Heim, P.E. DATE: ___2/23/2023___________________________________

DocuSign Envelope ID: CFBB6E9B-4617-4BEC-98F6-41A3863FECE2