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Home My WebLink AboutNC0024911_Pretreatment Audit_20240820 August 20, 2024 Thomas E Hartye Metropolitan Sewerage District of Buncombe County North Carolina Email: thartye@msdbc.org SUBJECT: Compliance Inspection Report-Pretreatment Audit MSD-Buncombe County NPDES WW Permit No. NC0024911 Buncombe County Dear Permittee: The North Carolina Division of Water Resources conducted an audit of the Metropolitan Sewerage District’s pretreatment program on 7/29/2024. This inspection was conducted to verify that the program is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0024911 and 15 NCAC 02H.0900. The findings and comments noted during the audit are included in the attached reports. There were no significant issues or findings noted during the inspection and therefore, a response to this inspection report is not required. If you should have any questions, please do not hesitate to contact Mikal Willmer with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4686or via email at mikal.willmer@deq.nc.gov. Sincerely, Andrew Moore, Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Pretreatment Audit & Inspection Report Ec: Shannon Bergeron, MSD Chad Ledford, MSD LF Docusign Envelope ID: 8BF971AD-EA7E-4108-9ACC-3CEA8D05F5CB 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 24/07/29 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) French Broad River WRF NC Hwy 251 Asheville NC 28814 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:30AM 24/07/29 24/05/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Other Facility Data 03:30PM 24/07/29 28/12/31 Name, Address of Responsible Official/Title/Phone and Fax Number Thomas E Hartye,2028 Riverside Dr Asheville NC 288043054//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 Melanie Kemp DWR/ARO WQ/ - - / Lauren E Armeni DWR/ARO WQ/828-296-4500/ Rachel Rose DWR/ARO WQ/828-296-4500/ Richard Eguino DWR/ARO WQ/828-296-4500/ Mikal Willmer DWR/ARO WQ/828-296-4686/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date Andrew W Moore DWR/ARO WQ/828-296-4684/ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page#1 Docusign Envelope ID: 8BF971AD-EA7E-4108-9ACC-3CEA8D05F5CB 8/20/2024 8/20/2024 8/22/2024 8/20/2024 8/20/2024 8/22/2024 NPDES yr/mo/day 24/07/29 Inspection Type G3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Mikal Willmer, Lauren Armeni, Richard Eguino, Melanie Kemp and Rachel Rose, with the Asheville Regional Office and Octavio Henriques, Central Office, conducted an Audit of the Metropolitan Sewerage District's (MSD) Pretreatment Program on July 29, 2024. This audit was conducted to determine whether the program is being operated and maintained in compliance with the pretreatment requirements outlined in NPDES Permit #NC0024911's standard conditions and 02H.0900. Shannon Bergeron & Chad Ledford with MSD were present and assisted in the Audit. Overall, the industrial pretreatment program is being well maintained and managed. MSD takes a proactive approach to streamlining data submittal and tracking. The use of an online system (Industrial BMP) allows staff to access an industry's information while in the field and while onsite for inspections. MSD actively works with non-compliant facilities to achieve compliance and find long-term solutions to reduce loadings on the WWTP. The program would benefit significantly from extra staffing for the industrial pretreatment program. Currently Ms. Bergeron is the only employee dedicated to overseeing 19 SIUs, soon to be 20, 11 of which are CIUs. There are also over 140 breweries, cideries, distilleries, etc. connected to the system and this number continues to grow as the service area expands. The Pretreatment Audit is attached for your records. NC0024911 17 (Cont.) Page#2 Docusign Envelope ID: 8BF971AD-EA7E-4108-9ACC-3CEA8D05F5CB Permit:NC0024911 Inspection Date:07/29/2024 Owner - Facility: Inspection Type: French Broad River WRF Pretreatment Audit Yes No NA NE Page#3 Docusign Envelope ID: 8BF971AD-EA7E-4108-9ACC-3CEA8D05F5CB 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: Metropolitan Sewerage District of Buncombe County 2. Control Authority Representative(s): Shannon Bergeron & Chad Ledford 3. Title(s): Industrial Pretreatment Coordinator & Pretreatment Supervisor 4. Address of POTW: Mailing 2028 Riverside Drive City Asheville Zip Code 28804 Phone Number (828) 254-9646 Fax Number E-Mail sbergeron@msdbc.org or cledford@msdbc.org 5. Audit Date 07/29/2024 6. Last Inspection Date: 02/23/2023 Inspection Type: PCI Audit 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. No chronic compliance problems. One unauthorized bypass of primary sludge due to an equipment failure and one BOD exceedance. 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 4 9 1 1 07 29 24 10. Current Number of Significant Industrial Users (SIUs)? 19 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? 0 13. Number of SIUs Not Sampled by POTW in Last Calendar Year? 0 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? N/A 17. Number of SIUs on Schedules? 0 18. Current Number of Categorical Industrial Users (CIUs)? 11 19. Number of CIUs in SNC? 0 Docusign Envelope ID: 8BF971AD-EA7E-4108-9ACC-3CEA8D05F5CB 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) 4/2/24 Yes No 7/10/19 Yes No N/A-submitted Industrial Waste Survey (IWS) 10/31/2019 Yes No 4/02/2020 Yes No 11/01/24-see summary at end of report Sewer Use Ordinance (SUO) 4/11/22 Yes No See audit summary Yes No N/A Enforcement Response Plan (ERP) 6/30/2020 Yes No 9/22/2020 Yes No Long Term Monitoring Plan (LTMP) 8/16/2019 Yes No 10/21/2019 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? Yes No If yes, Please list these towns and/or areas. Cane Creek sewer is now a part of MSD. 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 04/20/2020 25. Have you had any problems interpreting or enforcing any part of the SUO? Yes No If yes, Explain. Ms. Bergeron reports no major issues enforcing SUO. MSD will likely make minor adjustments soon. 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. MSD also maintains a copy of the ERP on their website, and industries are reminded about the ERP during their annual inspections. 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 No industries currently under a schedule or order of compliance. 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 Only one staff member focused on industrial pretreatment for 19, soon to be 20 SIUs, 11 of which are CIUs. MSD also has over 140 breweries/cideries etc. that require some level of oversite. Access to POTW Vehicles for Sampling, Inspections, and Emergencies S M U MSD is getting two new vehicles. Access to Operable Sampling Equipment S M U Attempt to purchase a couple new samplers every year. Availability of Funds if Needed for Additional Sampling and/or Analysis S M U Reference Materials S M U Docusign Envelope ID: 8BF971AD-EA7E-4108-9ACC-3CEA8D05F5CB NC DWR Pretreatment Audit Form Revised: December 2016 Page 3 Staff Training (i.e. Annual and Regional Workshops, Etc.) S M U Personnel can attend certification trainings and conferences throughout the year. Computer Equipment (Hardware and Software) S M U Upgrading from Access to Industrial BMP that allows for further digitization of the program. 30. Does the POTW have an adequate data management system to run the pretreatment program? Yes No Explain Yes or No. Industrial BMP software provides electronic inspections and access to facility information while in the field. It also provides an interface for the industries to interact with directly. MSD is currently using both Access and Industrial BMP while they are in the process of switching to the Industrial BMP software. 31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. Primarily through sewer use fees. 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? Would provide information electronically or have them come in for a file review. 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 confi dential from public. If no how would the request be addressed? MSD determines whether things are classified as a trade secret or confidential information and these files are locked in the Pretreatment Coordinator’s office and kept separate from the other files. 35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? Yes No Yes, if causing issues; however, due to staffing they are unable to meet more regularly with all industries. 36. Is the public notified about changes in the SUO or Local Limits? Yes No Changes in the SUO are published on MSDs website and mailers are sent out with any changes. 37. Were all industries in SNC published in the last notice? Yes No Permitting (Industrial Waste Survey-IWS) 38. How does the POTW become aware of new or changed Users? Planning and Development Department, Chamber of Commerce, conversations with industry, Manufacturers Directory, and occasionally through the local newspaper 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?) Based on facility flows, waste composition or whether they are a categorical industry. Some are based on audits of MSDs service area. 40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate? Yes No If Yes, How many are there? Five Please list each site and how it is permitted, if applicable. Duke landfill leachate (local groundwater permit), Chemtronics (local groundwater permit), Charra (local permit), Unison (local permit), and Buncombe County Landfill. 41. Does the POTW accept waste by (mark if applicable) Truck Dedicated Pipe NA Buncombe County Landfill Leachate is trucked to MSD. Gaia herbs is now discharging hauled process wastewater to a manhole located at their Arden location. 42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn, manifests required) Landfill leachate is discharged into a manhole across from the WWTP. A camera is constantly monitoring the location and loads are to be reported to MSDs Director. 43. How does the POTW allocate its loading to industries? Mark all that apply Docusign Envelope ID: 8BF971AD-EA7E-4108-9ACC-3CEA8D05F5CB NC DWR Pretreatment Audit Form Revised: December 2016 Page 4 Uniform Limits Historical Industry Need By Surcharge Categorical Limits Other Explain Other: Typically based on industry need or Categorical limits, but will implement local limits if more restrictive. 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? Silver due to limit set by the State. 45. If yes to #44, What is being done to address the over allocations? (short -term IUPs, HWA to be revised, pollutant study, etc.) MSD continually monitors the WWTP’s influent and effluent and they are continually below detection. 46. Does the POTW keep pollutant loading in reserve for future growth / safety? Yes No If yes, what percentage of each parameter ? Approximately 20%. MSD retains the minimum 10% out of the allocation table as a buffer. 47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) Yes 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) Some through the IWS, CIU limits, and discussions with industries. 49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain. Usually all are 2x/month or 1x/week depending on industry. This can be reduced to once a month with compliance. Permits are modified as needed. 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. Per MSDs ERP. Notices and penalties are retained on file. The BMP system helps flag exceedances. Public notices for SIUs in SNC are retained on file for review and submitted with the PAR. 52. Does the POTW use the Division’s model inspection form or equivalent? Yes No Inspection form has been modified to remove redundant information and is housed digitally in their Industrial BMP software. 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. 54. What criteria are used to determine if a slug/spill control plan is needed? MSD has documented Guidelines for Slug/Spill plan that is provided to all industrial users . All SIUs are required to have one. 55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? See above. Based on MSDs Guidelines: Facility layout and flow diagram, hazardous materials, discharge practices, slug prevention, emergency response, notification, training, and certification. 56. How does the POTW decide where the sample point for an SIU should be located? As close to the area of production or pretreatment as possible. 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. MSD has PACE sample their industries and MSD has provided hands on training with industries for sampling and interpreting their permit. Docusign Envelope ID: 8BF971AD-EA7E-4108-9ACC-3CEA8D05F5CB NC DWR Pretreatment Audit Form Revised: December 2016 Page 5 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 utilizes their standard Chain of Custody form and procedures for ensuring samples are collec ted in appropriate bottles and that appropriate preservatives are used and temperatures are met. Chains of Custody are signed when receiving and relinquishing custody. 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:__Beryllium-due to groundwater__________ 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 MSD submitted revised HWA in April 2024. 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 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 mo re land for sludge disposal)? Yes No Explain. Upgrades to the plant are the long-term solution for increasing BOD loads. Summary 65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? WWTP upgrades. Docusign Envelope ID: 8BF971AD-EA7E-4108-9ACC-3CEA8D05F5CB 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. Milkco, Inc. 2. Linamar Light Metals 3. Prince Manufacturing 67. IUP Number S-036 S-076 S-065 68. Does File Contain Current Permit? Yes No Yes No Yes No 69. Permit Expiration Date 12/31/26 12/31/26 12/31/26 70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A N/A 464.16 433 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, Does 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 Yes No N/A Yes No N/A 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: All files were readily available for DWR staff to review . MilkCo had BOD exceedance in April 24, but following day’s result was within limits. An NOV was issued in May 2024. Docusign Envelope ID: 8BF971AD-EA7E-4108-9ACC-3CEA8D05F5CB 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 4 9 1 1 07 29 24 1. Industry Inspected: Milkco, Inc 2. Industry Address: 220 Deaverview Road 3. Type of Industry/Product: Dairy product packaging 4. Industry Contact: David Clark Title: Environmental & Safety Manager Phone: 828-254-9560 Email: dclark@milkco.com 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 SIU inspection was conducted in person on 7/29/2024 and a follow up call on 7/30/2024 concluded the overall inspection. MSD conducted a thorough inspection of Milkco’s production area, chemical storage in relation to floor drains, catch basins near the raw milk unloading bay and sampling location. Currently Milkco does not have a pretreatment system, nor can they valve off or store process wastewater in the event of a bad batch, spill or leak. MSD Pretreatment staff have scheduled a time with Milkco to discuss adding pretreatment or storage to reduce slug loading the WWTP. Ms. Bergeron documented, discussed and provided a list of required and recommended improvements after the facility walkthrough. Audit SUMMARY AND COMMENTS: Audit Comments: MSD demonstrated a comprehensive knowledge and implementation of the pretreatment program. They are actively working with industries to maintain compliance . Central Office pretreatment staff are working on generating an approval letter for the most recent sewer use ordinance and should be issuing to MSD soon. MSD indicated they are working on the IWS for submittal by November 2024. Mr. Henriquez indicated Central Office is moving away from a submittal every five years to encourage a more proactive annual assessment of the potential industrial users connected to municipal system s. Requirements: Recommendations: There is currently one person dedicated to the industrial pretreatment program to manage 19 SIUs, 11 of which are CIUs. In addition to the SIUs, MSD has over 140 breweries, cideries, distilleries etc. discharging to their system. Ms. Bergeron would like to monitor these users more closely and regularly; however, due to staffing shortages, MSD is unable to take on additional inspections and monitoring requirements. It is highly recommended, and has been previously recommended, by the Division to consider increasing staffing for the industrial pretreatment program as demands on the system continue to increase. Ms. Bergeron indicated the number of SIUs is increasing to 20 soon. NOD: Yes No NOV: Yes No QNCR: Yes No Docusign Envelope ID: 8BF971AD-EA7E-4108-9ACC-3CEA8D05F5CB NC DWR Pretreatment Audit Form Revised: December 2016 Page 8 POTW Rating: Satisfactory Marginal Unsatisfactory Audit COMPLETED BY: Mikal Willmer DATE: 07/30/2024 Octavio Henriquez, Pretreatment Municipal Permitting, Lauren Armeni, Richard Eguino, Melanie Kemp & Rachel Rose, Asheville Regional Office Docusign Envelope ID: 8BF971AD-EA7E-4108-9ACC-3CEA8D05F5CB 8/20/2024