NC0060534_PCI_20241014

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

October 14, 2024

Wilson Hooper
Email: [e-mail]
City of Brevard

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 Pretreatment
Program on 9/03/2024. This inspection was conducted to verify that the program is operating in compliance
with the conditions and limitations specified in NPDES WW Permit No. NC0060534. The findings and
comments noted during this inspection are provided in the enclosed copy of the inspection report entitled
"Compliance Inspection Report".

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 me at 828-296-4686 or via email at
[e-mail].

Sincerely,

Mikal Willmer, Environmental Program Consultant
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: PCI & Inspection Report

Ec: LF
Docusign Envelope ID: 9DE4CEA1-02C9-4477-B777-D51CE859763A
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 NC0060534 24/09/03 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)
Brevard WWTP
3226 Wilson Rd
Pisgah Forest NC 28768
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
09:40AM 24/09/03 23/05/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Other Facility Data
11:00AM 24/09/03 27/09/30
Name, Address of Responsible Official/Title/Phone and Fax Number
Wilson Hooper,95 W Main St Brevard NC 28712//828-884-2770/8288842358 Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Other
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
Mikal Willmer DWR/ARO WQ/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: 9DE4CEA1-02C9-4477-B777-D51CE859763A
10/14/2024
10/14/2024
NPDES yr/mo/day
24/09/03
Inspection Type
P3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Mikal Willmer, with the Asheville Regional Office, conducted a Compliance Evaulation Inspection of
the City of Brevard's Pretreatment Program on September 3, 2024. This inspection was conducted to
determine whether the program is being maintained in compliance with the pretreatment requirements
established in the NPDES Permit Standard Conditions and 02H.0900. Tom Williams, Pretreatment
Coordinator, was present and assisted in the inspection.
Overall, the program appeared to be mainatined in compliance with rule and permit requirements.
Brevard currently only has one Significant Industrial User (SIU), Oskar Blues. The violations noted in
the previous Compliance Inspection appear to have been resolved. Mr. Williams has been working
with Pretreatment Staff in Central Office to finalize the updated head works analysis and they are
aware of the delay in submittal. The LTMP and IWS were submitted in December of 2023 and
acknowledgement emails were sent to the permittee. It should be noted that Central Office is no
longer requiring IWS submittals every five years. Oskar Blue's was not in SNC for the two
semi-annual montioring periods in 2023. The SIU exceeded there monthly average BOD loading limit
for May and June of 2024, but are not in SNC.
Discussions with Brevard staff indicate the potential for the addition of a CIU in the future; however, it
is unknown if/when this would occur.
NC0060534 17 (Cont.)
Page#2
Docusign Envelope ID: 9DE4CEA1-02C9-4477-B777-D51CE859763A
Permit:NC0060534
Inspection Date:09/03/2024
Owner - Facility:
Inspection Type:
Brevard WWTP
Pretreatment Compliance
Other Yes No NA NE
Comment:
Page#3
Docusign Envelope ID: 9DE4CEA1-02C9-4477-B777-D51CE859763A
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: Brevard
2. Control Authority Representative(s): Tom Wiliams
3. Title(s): Pretreatment Coordinator/ORC
4. Last Inspection Date: 9/26/23 Inspection Type (Check One): PCI Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? YES NO
6. Is POTW under an Order That Includes Pretreatment Conditions? YES NO
Order Type, Number, Parameters: _______________________________ Are Milestone Dates Being Met? YES NO

ICIS CODING
Main Program Permit Number MM/DD/YY
| N | C | 0 | 0 | 6 | 0 | 5 | 3 | 4 | | 09 | 03 | 24 |

7. Current Number Of Significant Industrial Users (SIUs)? 1
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)? 0
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
WWTP is piloting
PAA as
disinfectant.

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 NO
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:0
SNC for Reporting:0
Not Published:0
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?

NA

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

LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? YES NO
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? YES NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? YES NO Is Table Adequate? YES NO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? YES NO Inspector, please verify yourself!
26. If NO to 23 - 26, list violations _______________________________________________________________________________

Docusign Envelope ID: 9DE4CEA1-02C9-4477-B777-D51CE859763A
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? YES NO
If yes, which ones? Eliminated: Program removed metals since not used by industry
Added:_______________________
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) See
Summary
Yes No 1/31/2019 Yes No 8/1/23-See
summary
Industrial Waste Survey (IWS) 12/19/23 Yes No Yes No No longer
required by
Pretreatment
Central Office.
See summary
Sewer Use Ordinance (SUO) 11/21/2013

Yes No 12/13/2013 Yes No
Enforcement Response Plan (ERP) 7/13/2020 Yes No 9/23/2020 Yes No
Long Term Monitoring Plan (LTMP) 12/29/2023 Yes No Yes No See summary
________________________________________________________________________________________________________________
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. Oskar Blues 2. 3.
30. IUP Number 1
31. Does File Contain Current Permit? Yes No Yes No Yes No
32. Permit Expiration Date 08/31/2027
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 Yes No Yes No
35. Does File Contain an Inspection Completed Within Last Calendar Year? Yes No Yes No 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. Yes No
b. Yes No
a. Yes No
b. Yes No
a. Yes No
b. Yes No
37. 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
38. a. Does File Contain Original Permit Review Letter from the 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
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
Yes No Yes No Yes No
40. Does File Contain POTW Sampling Chain-Of-Custody Forms? Yes No Yes No Yes No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
Yes No N/A Yes No N/A Yes No N/A
41b. During the Most Recent Semi-Annual Period, Did SIU submit all reports
on time?
Yes No N/A Yes No N/A Yes No N/A
42a. 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
42b. For categorical IUs with Production based limit s, does file include
production rates and/or flows as Required by IUP?
Yes No N/A Yes No N/A Yes No N/A
43a. During the Most Recent Semi-Annual Period, Did the POTW Identify
All Limits Non-Compliance from Both POTW and SIU Sampling?
Yes No Yes No Yes No
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non-Compliance from SIU Sampling?
Yes No N/A Yes No N/A Yes No N/A
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 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
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC? Yes No Yes No Yes No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken Yes No N/A Yes No N/A Yes No N/A
Docusign Envelope ID: 9DE4CEA1-02C9-4477-B777-D51CE859763A
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
48. Does the File Contain Penalty Assessment Notices? Yes No N/A Yes No N/A Yes No N/A
49. Does The File Contain Proof Of Penalty Collect ion? Yes No N/A Yes No N/A Yes No N/A
50. a. Does the 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
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
Yes No Yes No Yes No

FILE REVIEW COMMENTS:
ORC has been in communication with pretreatment regarding the delay in his HWA. The IWC and LTMP were submitted on
12/29/23 to pretreatment and an acknowledgement was received. Pretreatment has not issued the “approval” for the LTMP yet.
IWS is no longer required to be submitted. Oskar Blues had two monthly BOD exceedances, but the City has been working with
them to resolve the issue.

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
| N | C | 0 | 0 | 6 | 0 | 5 | 3 | 4 | | 09 | 03 | 24 |

1. Industry Inspected:________________________________________________________________________________________
2. Industry Address:__________________________________________________________________________________________
3. Type of Industry/Product:___________________________________________________________________________________
4. Industry Contact:________________________________________Title:_____________________________________________
Phone:__________________________________________Fax:_____________________________________________
5. Does the POTW Use the Division Model Inspection For m 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:

OVERALL SUMMARY AND COMMENTS:
Comments: Only a file review was conducted of Oskar B lue’s pretreatment records. Please see the file review comments regarding items
related to paperwork. Brevard staff indicated they have a good working relationship with their SIU and that they communicate regarding
any non-compliance event. Continue to monitor any BOD exceedances for potential SNC situations per the definition in 02H.0900.
Requirements: Even though pretreatment is aware of the delay, please submit the updated Headworks Analysis as soon as possible since the
permit was updated in 2023.
Recommendations:

Docusign Envelope ID: 9DE4CEA1-02C9-4477-B777-D51CE859763A
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4
NOD: YES NO
NOV: YES NO
QNCR: YES NO
POTW Rating:
Satisfactory Marginal UnSatisfactory

PCI COMPLETED BY: Mikal Willmer DATE: ____09/23/2024_________________________________

Docusign Envelope ID: 9DE4CEA1-02C9-4477-B777-D51CE859763A
X
10/14/2024