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HomeMy WebLinkAboutNC0049867_Regional Office Historical File Pre 2018w Water Resources Environmental Quality April 26, 2017 The Honorable Danny Gabriel, Mayor Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 ROY COOPER Governor MICHAEL S. REGAN Secretary- S. JAY ZIMMERMAN Director Subject: PAR Review Town of Cleveland WWTP NPDES Permit No. NCO049867 Rowan County Dear Mayor Gabriel: Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR) for the reporting period of January through December 2016. Based on the review, the POTW completed the PAR in accordance with 15A NCAC 2H .0908(b) requirements and guidelines set forth in Comprehensive Guidance for North Carolina Pretreatment Programs. The next PAR will be due March 1, 2018. If you have any questions concerning your PAR, please do not hesitate to contact me at (704) 235-2192 and/or Monti Hassan at (919) 807-6314 or at wes.bell@ncdenr.gov and monti.hassangncdenr. gov. cc: Monti Hassan, PERCS Unit MSC-1617 Central -Basement Sincerely, 6 ram W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ State of North Carolina I Environmental Quality) Water Resources I Water Quality Regional Operations Mooresville Regional Office 1 610 East Center Avenue, Suite 3101 Mooresville, North Carolina 281.15 704-663-1699 Water Resources ENVIRONMENTAL QUALITY PAT MCCRORY t Governor D, �- ONALD{ 93 �1AN DER VA:ART Secretary S. JAY ZIMMERM:AN Director August 22, 2016 The Honorable Danny Gabriel, Mayor Town of Cleveland. Post Office Box 429 Cleveland, North Carolina 27013 Subject: Notice of Deficiency Pretreatment Compliance, Inspection Town of Cleveland WWTP NPDES Permit No. NCO048967 Rowan County Tracking #: 14OD-2016-PC-0396 Dear Mayor Gabriel: Enclosed is a copy of the Pretreatment Compliance Inspection -Report for theinspection of the Town of Cleveland approved Industrial Pretreatment.Program on August 16, 20.16 by Mr: Wes Bell of this Office: Please inform the Town's Wastewater Consultants (Statesville Analytical) and WWTP ORC of our.findings by forwarding a copy of the enclosed report. This report is being issued as a Notice of Deficiency(NOD) due to. the Town's failure to properly implement the Pretreatment Program. Specifically, the Town failed to initiate enforcement according to the Division approved ERP on monitoring violations (pH and temperature) that.had occurred. throughout the January - June, 2016 review period. The Town must initiate enforcement actions. orf these.monitoring violations by September 9, 2016. In addition, it is;requested that a written response be submitted to this Office by September 19, 2016. addressing the actions taken to correct these noncompliant findings. In responding, please address your comments to Mr. Bell.. Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at (704) 235-2192 or email wes.bell =,ricdenr.gov. Sincerely, WB State.dNorth Carolina Environmental Quality I Water Resources I Water Quality Regional Operations.. . Mooresville Regional Office 1 610 East Center Avenue, Suite 3011 Mooresville, North Caolina 28115 . 704 663 1699 FaBACe' NORTH CAROLINA DIVISION OF WATER RESOURCES I�ICDENR PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT DeF frvumnMbuu.w. i0twa.KGROUND INFORMATION 1Comalete Prior To PCI; Review Proaram Info Database Sheet(s)1. 1. Control Authority (POTW) Name: Town of Cleveland 2. Control Authority Representative(s): Ms. Dena Myers, Mr. Todd Robinson 3. Title(s): Consultant —'Statesville Analytical, Inc., W WTP ORC 4. Last Inspection Date: 5/21/15 Inspection Type: ® 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 ®NA' PCS CODING Trans.Code Main Program Permit Number MM/DD/YY -Inspec.Type Inspector I NC0049867 08/16/16 P S (DTTA) (TYPI) (INSP) Fac. Type I (FACC) T. Current Number Of Si cant Industrial Users SIUs)? 1 sIUS 8. Current Number Of Categorical Industrial. Users CIUs)? . 1 CIUS 9. Number of SlUs 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. Enter the Higher Number of 9 or 10 0. NOIN 12. Number of SIUs With No IUP, or With an Expired lUP 0 NOCM .13. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2 0 : Semi -Annual Periods (Total Number of SIUs in SNC) pSNC 14. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods 0 MSNC 15. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods, _ 0 SNPS 16. Number of SAbs In SNC For Both Reporting and Limits Violations During Either of the Last 2 0 Semi-annual Periods 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? 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? 19. Which Industries have been in SNC for Limits or Reporting during SNC foi either of the Last 2 Semi -Annual Periods? Not Been Published for SNC foi PublicNotice?(May refer to PAR if Excessive SIUs in SNC) Not Pu 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? 21. Are Any Permits .Or Civil Penalties Currently Under Adjudication? If Yes,. Which .Ones?. YES ®NO El YES. ®NO Limits: None Reporting: None blished: NA ❑ YES NO LTMP/STMP FILE REVIEW: 22: Is.LTMP/STMP.Monitoring Being Conducted at Appropriate Locations and Frdquencies?; ®.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.7eported on Discharge Monitoring Report? ® YES ❑ NO 26. If NO to. 23 - 26, list violations: '' 27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ®NO NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 1 28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files verify POTW has copy ofProgram. Ele their files, complete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Program Info: Headworks Analysis (HWA) 6/7/12 ® Yes ❑ No 11/20/12 ® Yes ❑ No 10/1/16 Industrial Waste Survey (IWS) 5/27/11 ® Yes ❑ No 6/24/11 ® Yes ❑ No 6/1/16 Sewer Use Ordinance SUO 1/18/13 ® Yes ❑ No 1/23/13 ® Yes ❑ No Enforcement Response Plan RP 7/15/09 ® Yes ❑ No 8/13/09 ® Yes El No_ Long Term Monitoring Plan (LTMP) 9/9/14 ® Yes El No 11/26/14 ® Yes El No Program Element Last Submittal Received Last Approval Date Nett Due, I Date - In file? Date . In file If Applicable INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP. FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION) 29. User Name IF 1. Daimler Trucks NA, LLC 2. 3. 30. IUP Number 0001 31. Does File Contain Current Permit? [:]Yes El Noll El Yes ❑ No El Yes El No 32. 'Permit Expiration Date 6/30/18 33. Categorical Standard Applied .E. 40 CFR, Etc.) Or N/A 433.17 34. Does File Contain Permit Application Completed Within One Year Prior ® Yes ❑ No FM'TeTE] No ❑ Yes El No to Permit Issue Date? 35. Does File Contain an Ins ection Com leted Within Last Calendar Year? ® Yes El No El Yes ❑ No El Yes El No 36. a. Does the File Contain.a Slug/Spill Control Plan? a. ®Yes ONO a. []YesNo ❑ Fa. Yes ❑No b. If No, is One Needed? See Inspection Form from POT b. []Yes No b. Yes No b. Yes ❑No []Yes 37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic ❑Yes❑NoON/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Organic Management Plan (TOW)? 38. a. Does File Contain Original Permit Review Letter from the Division? a. ®Yes ❑No a. []Yes []No a. []Yes ❑No b. All Issues Resolved? b.❑Yes❑No®N/A b.pYes❑No❑N/A b.❑Yes❑No❑N/A 39. During the Most Recent Semi -Annual Period, Did the POTW Complete ® Yes ❑ No ❑ Yes El No El Yes' El No its Sampling as Required b IUP, includingflow? 40. Does File Contain POTW Sampling Chain-Of-CustodyForms? ® Yes El ❑ Yes El No ❑ Yes El No 41a. During the Most Recent Semi -Annual Period, Did the SIU Complete its ❑Yes®No❑N/A ❑1[—Yes❑No❑N/A ❑Yes❑No❑N/A Sampling as Required b IUP, -includingflow? 41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports ®Yes❑No❑N/A ❑Yes❑No❑N/A 11 ❑Yes❑No❑N/A on time? 42a. For categorical lUs with Combined Wastestream Formula (CWF), does ®Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 11 file include process/dilution flows as Required b rUP? 42b. For categorical IUs with Production based limits, does file include ❑Yes❑NoON/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A production rates and/or flows as Required b IUP? 43a. During the Most Recent Semi -Annual Period, Did the POTW Identify ❑Yes❑No®NA ❑Yes❑No❑N/A ❑Yes❑No❑N/A All Limits Non -Compliance from Both POTW and SIU Sampling? 43b. During the Most Recent Semi -Annual Period, Did the POTW Identify ❑Yes®No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A . All Reporting Non -Compliance from SIU Sampling? 44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self- a.❑Yes❑No®N/A a.❑Yes❑No❑N/A a.❑Yes❑No❑N/A Monitoring Violations? b. Did Industry Resample and submit results to POTW Within 30 Days7 b.❑Yes❑No®N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A c. Did POTW resample within 30 days of knowledge of SIU limit c.❑Yes❑No®N/A c.❑Yes❑No❑N/A c.❑Yes❑No❑N/A violations from the POTW sample event? 45. Duringthe Most Recent Semi -Annual Period, Was the SIU in SNC? ❑ Yes ® No ❑ Yes [I No El Yes El No 46. During the Most Recent Semi -Annual Period, Was Enforcement Taken ❑Yes®No❑N/A 1[0Yes0No[3N/A ❑Yes❑No❑N/A as Specified in the POTW s ERP OVs, Penalties, timing, etc.)? 47. Does the File Contain Penal Assessment Notices? ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 48. Does The File Contain Proof Of Penal Collection? ❑Yes❑No®N/A ❑❑N/ Yes❑NoA ❑Yes❑No❑N/A 49. a. Does the File Contain Any Current Enforcement Orders? a.❑Yes❑No®N/A a.❑Yes❑No❑N/A a.❑Yes❑No❑N/A b. Is SIU in Compliance with Order? b.❑Yes❑No®N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A 50. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑ Yes ® No ❑ Yes ❑ No ❑ Yes ElNo Requested Information For You? NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2 The PERCS Unit received the IWS package on 7/6/16. The SUO was adopted on 11/6/12. 35. The last SIU inspections were performed on 2/9/15 and 6/29/16. 37. The SIU performs semiannual TTO sampling. TTO sampling was last performed in January 2016 and July 2016. 39. The POTW contracts Statesville Analytical to perform analyses. 41a. The SIU contracts Pace Analytical Services to perform analyses. The SIU did not perform pH and temperature on a daily basis at Pipe 002 as required by the IUP,. Note: Daily Monitoring Frequency as specified in the IUP means each day of discharge (Permit Condition Reference: Part I, G(3) = Daily Monitoring Frequency). 43b. The POTW failed to identify. the pH and temperature monitoring violations at Pipe 002 throughout the January — June 2016 .review period. 46.. The POTW failed to initiate enforcement on the pH and temperature violations (Pipe 002) according to the Division approved ERP. SUMMARY AND COMMENTS: Comments: The POTW must ensure to all SIU monitoring reports are reviewed for ]UP compliance and appropriate enforcement is initiated according to the Division approved ERP. The records reviewed during the inspection were organized and well maintained. Overall, the POTW's pretreatment program appeared to be adequately managed. Requirements: The POTW shall initiate enforcement for all pH and temperature monitoring violations (Pipe 002) during the January — June 2016 i period according to the Division approved ERP by September 9, 2016. NOD: EYES ❑ NO 'NOV: ❑ YES ® NO QNCR: ❑. YES ® NO POTW Rating: Satisfactory ® Marginal. ❑ Unsatisfactory_ ❑ PCI COMPLETED BY: DATE: August 22, 2016 Wes Bell, Mooresville Regional Office NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3 Water Resources ENVIRONMENTAL QUALITY The Honorable Danny Gabriel, Mayor Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Dear Mayor Gabriel: PAT MCCRORY Governor D{�ONALD R, VAN DER VAART ' M Secretaiy y 1. L JAY ZIMMERMAN Director April 26, 2016 ' Subject: PAR Review Town of Cleveland WWTP NPDES Permit No. NCO040867 Rowan County Mooresville Regional Office staff has reviewed your Pretreatment. Annual Report (PAR) for the reporting period of January through December 2015. Based on the review, the POTW completed the PAR in accordance with 15A NCAC 2H .0908(b) requirements and guidelines set forth. in Comprehensive Guidance for North Carolina Pretreatment Programs. The next PAR will be due• March 1, 2017'. If you have any questions concerning your PAR, please do not hesitate to contact Mr. Wes Bell at (704) 23.5-2192 and/or. Mr. Monti Hassan at (919) 807-6314 or at wes.bellgncdenr. gov. and monti.hassan@ncdenr.gov. Sincerely, . a. W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ cc: Monti Hassan, PERCS Unit MSC-1617 Central -Basement ENO.] State of North Carolina Environmental Quality I Water Resources I Water Quality Regional Operations Mooresville Regional Office 1 610 East Center Avenue; Suite 3011 Mooresville, North Carolina 28115 704 663 1699 r"' -A rA F�LE WDENR North Carolina Department of Environment and Natural Resources Pat McCrory Donald van der Vaart Governor Secretary April 16, 2015 The Honorable Danny Gabriel, Mayor Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Subject: PAR Review Town of Cleveland WWT.P NPDES Permit No. N00049867 Rowan County Dear Mayor Gabriel: Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR) for the reporting period of January through December 2014. Based on the review, the POTW completed the PAR in accordance with 15A NCAC 2H .0908(b) requirements and guidelines set forth in Comprehensive Guidance for North Carolina Pretreatment Programs. The next PAR will be due March 1, 2016. If you have any questions concerning your PAR, please do not hesitate to contact me at (704) 235-2192 and/or Monti Hassan at (919) 807-6314 or at wes.bell cr icdenr.gov and monti.hassan@a ncdenr.gov. Sincerely, Wes Bell Environmental Specialist Water Quality Regional Operations Section cc: Monti Hassan, PERCS Unit Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org An Equal Opportunity 1 Attirmative Action Employer — 30% Recycled; l0% Post Consumer paper • o rr -,)LE NC®ENIt North Carolina Department of Environment and Natural Resources Division of Water Resources Water Quality Programs Pat McCrory Thomas A. Reeder John E. Skvarla, III Governor Director Secretary March 24, 2014 The Honorable Danny Gabriel, Mayor Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Subject: PAR Review Town of Cleveland W WTP NPDES Permit No. NCO049867 Rowan County Dear Mayor Gabriel: Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR) for the reporting period of January through December 2013. Based on the review, the POTW completed the PAR in accordance with 15A NCAC 2H .0908(b) requirements and guidelines set forth in Comprehensive Guidance for North Carolina Pretreatment Programs. The next PAR will be due March 1, 2015. If you have any questions concerning your PAR, please do not hesitate to contact me at (704) 235-2192 and/or Monti.Hassan at (919) 807-6314 or at wes.bell@.nedeilr.gov and monti.hassannncdenr.gov. Sincerely, (71 Wes Bell Environmental Specialist Water Quality Regional Operations Section cc: Monti Hassan, PERCS Unit Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service: 1-877-623-6748 Internet: www.newaterquality.org NorthCarolina ;Vatmrl ll,ff An Fnual nnnnrfunifv l Affirmnfiva Arfinn Fmnlnvr.r — ino,, Racvrlari/1n% Pnst Cnnsmnar nanar L E NcA4 eFN�a North Carolina Department of Environment and Natural Resources Division of Water Resources Water Quality Programs Pat McCrory Thomas A. Reeder John E. Skvarla, III Governor Director Secretary September 4, 2013 The Honorable John I. Steele, Jr., Mayor Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Subject: Pretreatment Audit Inspection Cleveland WWTP NPDES Permit No. NCO049867 Rowan County Dear Mayor Steele: Enclosed is a copy of the Pretreatment Audit Inspection Report for the inspection of the Town of Cleveland approved Industrial Pretreatment Program on August 26, 2013 by Mr. Wes Bell of this Office. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at (704) 235-2192 or at wes.bellancdenr.gov. Sincerely, Michael L. Parker J Regional Supervisor Surface Water Protection Section Enclosure: Inspection Report cc: Central Files Monti Hassan, PERCS Unit Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service: 1-877-623-6748 Internet: www.ncwaterqualit .org One NorthCarohna NatilrallrY An Equal Opportunity, Affirmative Action Employer — 30% Recycledi10% Post Consumer paper Ao`' F W Ar�9QG — TPA NORTH CAROLINA DIVISION OF WATER QUALITY 7 NCDENR PRETREATMENT AUDIT REPORT o Background Information: 1. Control Authority (POTW) Name: Town of Cleveland 2. Control Authority Representative(s): Dena Myers, Tracy Moore, and Patrick Phifer 3. Title(s): Statesville Analytical/Consultants (Dena and Tracy) and Town of Cleveland POTW Director 4. Address of POTW: Street/Post Office Box PO Box 429 City/State/Zip Code Cleveland, NC 27013 Phone Number Statesville Analytical 704-872-4697 Fax Number 704-878-2787 E-Mail denamyers(abellsouth.net POTW Director 704-278-3602 5. Audit Date 08/26/2013 6. Last Inspection Date: 03/8/2012 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. The POTW's WWTP reported a monthly average ammonia violation in April 2012, a weekly average fecal coliform violation in July 2012, and a weekly average TSS violation in April 2013. 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 PCS (WENDB)Codin2: Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type LEI INIC10 IO I4 I9 I8 I6 I7 I08 I26I13I (DTIA) (TYPI) (INSP) (FACC) .10:..._Current Number of Significant Industrial Users(SIUS)?..........................:.................................................................................................. 1 SILTS ........................... 11.:... Current Number of Categorical Industrial Users (CIUS)? 1. CIUS .......................... 12. Number of SIUs Not Inspected. by POTW in Last Calendar Year? 0 .................................................................................................................................................... .......................... 13. Number of SlUs Not Sampled by POTW in Last Calendar Year? 0 ................................................................................................................................................................ ............... 14. Enter Higher Number of 12 or 13 0 NOIN ............................................................................................................................................................................................................................................................................................... ........................... 15. Number of SIUs with No IUP, or with an Expired IUP 0 NOCM ............................................................................................................................................................................................................................................................... ........................... 16. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of Last 2 0 PSNC Semi -Annual Periods Total Number of SIUs in..SNC .............................................................................................................................. .........................................................................(........................................................................................ 17. Number of SIUs in SNC for Reporting During Either. of Last. 2 Semi -Annual Periods 0 MSNC .......................................................................................................... ........................... 18. Number of SIUs in SNC for Limits Violations During. Either of 2 Semi -Annual Periods 0 SNPS ..................................................................... .... ........................... 19. Number of SIUs in SNC for Both Reporting and Limits Violations During Either of Last 2 0 Semi -Annual Periods 20. Number of SIUs in SNC for Self -Monitoring Requirements that were Not Inspected or Sampled 0 SNIN W. I WO Pretreatment Andit Fnrm Revised- 7iily 9.5. 7.007 Page 1 21. PRETREATMENT PROGRAM FLEMFNTS REVIEW Program Element: Cleveland WWTP Last Submittal Date In file? Last Approval Date In file Date Next D If Applicab Headworks Analysis (HWA) 6/7/12 ® Yes ❑ No 11/20/12 ® Yes ElNo 10/1/16 Industrial Waste Survey (IWS) 5/27/11 ® Yes ❑ No 6/24/11 ® Yes ❑ No 6/1/16 Sewer Use Ordinance (SUO) 1118113 ® Yes ElNo 1/23/13 ® Yes ❑ No Enforcement Response Plan (ERP) 7/15/09 ® Yes ❑ No 8/31/09 ® Yes ❑ No Long Term Monitoring Plan (LTMP) 1/25/07 ® Yes ❑ No 3/15/07 ® Yes ❑ No 9/1/14 ue, le Legal Authority (Sewer Use Ordinance-SUO) 22. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction? ElYes ® No If yes, Please list these towns and/or areas. 23. If yes to #22, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ElYes ElNo ® NA A copy, if not already submitted, should be sent to Division. 24. If yes to #22, Have you had any trouble working with these towns or districts? ❑ Yes ❑ No ® NA If yes, Explain. 25. Date of Last SUO Adoption by Local Council 11/5/2012 26. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No If yes, Explain. Enforcement (Enforcement Response Plan-ERP) 27. Did you send a copy of the ERP to your industries? ® Yes ❑ No If no, POTW must send copy within 30 days. 28. 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. 29. List Industries under a Schedule or Order and Type of Schedule or Order None Resources 30. Please Rate the Following: S=Satisfactory M=Mareinal U=Unsatisfactory Rating Explanation, if Unsatisfactory Personnel Available for Maintaining POTW's Pretreatment Program ®S ❑M ❑U Access to POTW Vehicles for Sampling, Inspections, and ®S Elm ❑U Emergencies Access to Operable Sampling Equipment ®S Elm ❑U Availability of Funds if Needed for Additional Sampling and/or Analysis ®S ❑M ❑U Reference Materials ®S ❑M ❑U Staff Training (i.e. Annual and Regional Workshops, Etc.) ®S ❑M ❑U Computer Equipment (Hardware and Software) ®S ❑M ❑U NC DWO Pretreatment Audit Form Revised: Julv 25. 2007 Pape 9. FI_ D1. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No Explain Yes or No. Statesville Analytical is on contract to administer the program. 32. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. Direct billing of costs to the SIU. Public Perception/ Participation: 33. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)? ❑ Yes ® No If yes, Explain. 34. 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? Make an appointment with the Town for file review, files would be reviewed at Town Hall. 35. 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? Confidential files would be maintained in locked cabinet. 36. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No Email is main form of communication. 37. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No 38. Were all industries in SNC published in the last notice? ❑ Yes ❑ No ® NA Permitting (Industrial Waste Survey-IWS): 39a... How does the POTW become aware of new or changed Users? All requests for new users goes through Town Hall and a package that includes IWS is given to prospective new users. 39b. 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 Town's pretreatment consultant reviews IWS and would contact the new user and perform site visits. 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) NA 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? 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 20% 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) NPDES Permit pollutants of concern and categorical parameters. NC DWO Pretreatment Audit Form Revised: Julv 25.2007 Pape 3 49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits ? Explain. The SIU is issued monthly monitoring requirements based on historical data. 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, reporting requirements, and permit conditions, as well as for SNC. Limits: evaluated each 6 month period for SNC (66% chronic and 33% TRC violations is SNC), late reporting is given a Notice of Violation, permit condition violations are evaluated on a case by case basis (SNC if there is a potential to impact WWTP). 52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No If no, does the POTW form include all DWQ 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? Based on observations (drains, chemical storage, containment, etc.) noted during the site visit. 55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? Review MSDS, activities plan, potential impact to WWTP. 56. How does the POTW decide where the sample point for an SIU should be located? Sampling points (two outfalls) include inside only process wastestream and an outside main sampling point that includes all wastewater discharged from SIU. 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. Written SOP for sampling and meter calibration 58. Who performs sample analysis for the POTW for Metals . Statesville Analytical, low level mercury - Meritech Conventional Parameters Statesville Analytical Organics - Enco 59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples. Commercial lab.Chain of Custody forms are used for all sampling. Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA): 60a. 60b. 60c. 60d. 60e. 60f. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO DWQ Inspector, verify yourself. If NO to any above, list violations 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? Statesville Analytical Phone (704) 872 - 4697 62. Do you have plans to revise your HWA in the near future? ❑ Yes ® No Next HWA due 10/1/16 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 (Crowders Creek WWTP) ®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. No need NC DWO Pretreatment Audit Form Revised: .iuly 25. 2007 Page 4 65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No INDUSTRIAL USER PERMIT (IUP) FILE REVIEW: 66. User Name 1. Daimler Trucks NA, LLC 2. 1 3. 67. IUP Number 0001 68. Does File Contain Current Permit? ® Yes ❑ No 11 ❑ Yes ❑ _N­o­jj ❑ Yes ❑ No 69. Permit Expiration Date 6/30/18 70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 433.17 71. Does File Contain Permit Application Completed Within One Year Prior ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No to Permit Issue Date? 72. Does File Contain Inspection Completed Within Last Calendar Year? ® Yes ❑ N=ol ❑ Yes ❑ No 11 ❑ Yes ❑ No 73. a. Does File Contain Slug/Spill Control Plan? a. ®Yes ❑No. a. ❑Yes ❑No ❑Yes ❑No b. If No, is One Needed? (See Inspection Form from POTW) b. ❑Yes ❑No b. ❑Yes ❑No Lb[]Yes ❑No 74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic ❑Yes❑NoNN/A ❑Yes❑No❑N/A ❑Yes❑NoNN/A Organic Management Plan (TOMP)? 75. a. Does File Contain Original Permit Review Letter from Division? a. ❑Yes ®No a. ❑Yes ❑NoIF-a. ❑Yes ❑No b. All Issues Resolved? b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A I b.❑Yes❑No❑N/A 76. During Most Recent Semi -Annual Period, Did POTW Complete its ® Yes ❑ No El Yes El No ❑ Yes Li No -11 Sampling as Required by IUP, including Flow? 77. Does File Contain POTW Sampling Chain -Of -Custody Forms? ® Yes ❑ No ❑ Yes ❑ No 11 ❑ Yes ❑ No 78. During Most Recent Semi -Annual Period, Did S1U Complete its NYes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Sampling as Required by IUP, includingFlow? 79. During Most Recent Semi -Annual Period, Did SILT submit all reports on NYes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A time? 80a. For categorical IUs with Combined Wastestream Formula (CWF), does NYes❑No❑N/A ❑Yes❑No❑N/A 11 ❑Yes❑No❑N/A file includeprocess/dilution flows as Required by IUP? 80b. For categorical IUs with Production based limits, does file include ❑Yes❑NoNN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A production rates and/or flows as Required by IUP? 81. During Most Recent Semi -Annual Period, Did POTW Identify All ❑Yes❑NoNN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Limits Non -Compliance from Both POTW and SIU Sampling? 82. During Most Recent Semi -Annual Period, Did POTW Identify All ❑Yes❑NoNN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Re ortin Non -Compliance from SILT Sampling? 83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self- a.❑Yes❑NoNN/A a.❑Yes❑No❑N/A a.❑Yes❑No❑N/A Monitoring Violations? b. Did Industry Resample and submit results to POTW within 30 Days? b.❑Yes❑No®N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A c. If applicable, did POTW resample and obtain results within 30 days of becomingaware of SIU limit violations in the POTW's sampling of SIU? c.❑Yes❑NoNN/A c.❑Yes❑No❑N/A c.❑Yes❑No❑N/A 84. During Most Recent Semi -Annual Period, Was SIU in SNC? I ❑ Yes ® No ❑ Yes ❑ No ❑ Yes ❑ No 85. During Most Recent Semi -Annual Period, Was Enforcement Taken as ❑Yes❑NoNN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 11 Specified in POTW's ERP (NOVs, Penalties, timing, etc.)? 11 86. Does File Contain Penalty Assessment Notices? ❑Yes❑NoNN/A ❑Yes❑No❑N/A 11 ❑Yes❑No❑N/A 87. Does File Contain Proof Of Penalty Collection? ❑Yes❑NoNN/A ❑Yes❑No❑N/A 11 ❑Yes❑No❑N/A 88. a. Does File Contain Any Current Enforcement Orders? a.❑Yes❑NoNN/A a.❑Yes❑No❑N/A loYesoNooN/A a.❑Yes❑No❑N/A b. Is SILT in Compliance with Order? b.❑Yes❑NoNN/A b.❑Yes❑No❑N/A 89. Did POTW Representative Have Difficulty in Obtaining Any Requested Yes ® No ElYes ❑ No ❑ Yes ❑ No Information For You? F FILE REVIEW COMMENTS: 72. The SIU inspection was conducted on 5/30/12. 74. The SIU conducts TTO sampling. 75. POTW has not received approval letter of recently issued SIU Permit. 76. The POTW collected all parameters except pH and temperature during the January - June 2013 period. 78. The SIU contracts Pace Analytical Services for sample analyses. 83. The SIU is required to conduct monthly sampling events. NC DWO Pretreatment Audit Form Revised: July 25.2007 Paee 5 INDUSTRY INSPECTION PCS CODING: Trans.Code Main Program Permit Number MM/DD/YY Inspection type ON N I C 10 10 14 19 18 16 17 1 108 126 1 13 1 UO (DTIA) (TYPI) 1. Industry Inspected: Daimler Trucks NA, LLC 2. Industry Address: 11550 Statesville Blvd., PO Box 399, Cleveland, NC 27013 3. Type of Industry/Product: Heavy Trucks Inspector Facility Type 0 (INSP) (FACC) 4. Industry Contact: Heather Callahan Title: Sr. Env. Engineer Phone:704-645-5353 Fax: 704-645-5404 5. Does the POTW Use the Division Model Inspection Form or Equivalent? M 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 M Yes ❑ No D. Sampling Review M Yes ❑ No E. Exit Interview M Yes ❑ No Industrial Inspection Comments: Physical Chemical treatment process including pH adjustment, chemical addition, and sludge settling. Sludge is dewatered by means of a plate press and transported by Republic Services to the VSL facility in S.C. The sludge is mixed with a higher btu value waste and used as a fuel in the cement making process. SUMMARY AND COMMENTS: Audit Comments: The Pretreatment Program files are well organized and maintained. All documentation was complete and up-to- date. Requirements: POTW staff must ensure all permit -required parameters (including pH and temperature) are collected during future sampling events. Recommendations: POTW must ensure all composite samples are collected and preserved according to 40 CFR 136.3. NOD: ❑ Yes M No NOV: ❑ Yes M No QNCR: ❑ Yes M No POTW Rating: Satisfactory M Marginal ❑ Unsatisfactory ❑ Audit COMPLETED BY: lti DATE: September 4, 2013 Wes Bell, Mooresville Regional Office NC DWO Pretreatment Audit Form Revised: July 25. 2007 Page 6 F-ILE NC®ENtt North Carolina Department of Environment and Natural Resources Division of Water Quality Pat McCrory Charles Wakild, P.E. John E. Skvarla, III Governor Director Secretary April 30, 2013 The Honorable John I. Steele, Jr., Mayor Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Subject: PAR Review Town of Cleveland WWT.P NPDES Permit No. NCO049867 Rowan County Dear Mayor Steele: Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR) for the reporting period of January through December 2012. Based on the review, the POTW completed the PAR in accordance with 15A NCAC 2H .0908(b) requirements and guidelines set forth in Comprehensive Guidance for North Carolina Pretreatment Programs. The next PAR will be due March 1, 2014. If you have any questions concerning your PAR, please do not hesitate to contact Donna Hood and myself at (704) 663-1699 and/or Monti Hassan at (919) 807-6314 or at dorma.hoodna,ncdenr.gov, wes.bell a,ncdenr.gov, and monti.hassaii@ncdem•.gov. Sincerely, Wes Bell Environmental Specialist Surface Water Protection Section cc: Monti Hassan, PERCS Unit Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org One . .One ltl" An Fnual Onnnrfunity 1 Affirmnfiva Anfinn PrnnInVPf —3n,/ RarvciP.&in% Pnct (`nnsiimar nanar Beverly Eaves Perdue Governor i" Lai ==0 J NC®ENR North Carolina Department of Environment and Natural Resources Division of Water Quality Charles Walcild, P. E Dee Freeman Director Secretary March 9, 2012 The Honorable John Steele, Jr., Mayor Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Subject: Pretreatment Compliance Inspection Town of Cleveland NPDES Permit No. NCO049867 Rowan County, NC Dear Mr. Mayor Steele: Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection conducted at the subject facility on March 8, 2012 by John Lesley and Wes Bell and Ms. Donna Hood of this office. Please forward a copy of this report to the Town's pretreatment program consultants. The report should be self-explanatory; however, should you have any questions Concerning this report, please do not hesitate to contact Mr. Lesley at (704) 663-1699. Sincerely, Robert B. Krebs ''7 Surface Water Protection Section Regional Supervisor Enclosure cc: Central Files Monti Hassan, PERCS Unit Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 25115 Phone: (704) 663-1699 \ Fax: (704) 663-6040 Internet: hltp:llportal.ncdenr.org/web/wq NorthCarolina ;V47turaI411 An Equal Opportunity \ Affirmative Action Employer— 50961 Recycled/104- Post Consumer paper NORTH CAROLINA DIVISION OF WATER QUALITY NCDENR PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)] WATFRQG r o 1. Control Authority (POTW) Name: Town of Cleveland 2. Control Authority Representative(s): Mr. Pat Phifer, Ms. Dena Myers, Ms. Tracy Moore 3. Title(s): Water/Sewer Commisoner, Consultants - Statesville Analytical 4. Last Inspection Date: 09/27/11 Inspection Type: M PCI ❑ Audit 5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? M YES ❑ NO 6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES M NO Order Type, Number, Parameters: Are Milestone Dates Being Met? ❑ YES ❑ NO M NA PCS CODING Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type N NCO049867 03/08/12 P S 1 (DTIA) (TYPI) (INSP) (FACC) 7. Current Number Of Significant Industrial Users (SIUs)? 1 SIUS 8. Current Number Of Categorical Industrial Users (CIUs)? 1 CIUS 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. Enter the Higher Number of 9 or 10 0 NOIN 12. Number of SIUs With No IUP, or With an Expired IUP 0 NOCM 13. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2 Semi -Annual Periods (Total Number of SIUs in SNC) 0 PSNC 14. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods 0 MSNC 15. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods�l 0 SNPS 16. Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2 Semi-annual Periods 11 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? 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? 19. Which Industries have been in SNC for Limits or Reporting during SNC foi either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pu 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? 21. Are Any Permits Or Civil Penalties Currently Under Adjudication? If Yes, Which Ones? ❑ YES ONO M YES ❑ NO IUP limit violations for Cr, and Zn Reporting violations- sent NOV and assessed $500.00. Limits: None Reporting: None dished: None None ❑ YES ONO LTMP/STMP FILE REVIEW: 22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? M YES ❑ NO 23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? M YES ❑ NO See Comments 24. Is LTMP/STMP Data Maintained in a Table or Equivalent? M YES M NO Is Table Adequate? M YES ❑ NO 25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? M YES ❑ NO 26. If NO to 23 - 26, list violations: 27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES M NO If yes, which ones? Eliminated: Added: NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7i'25'07 Page 1 28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element their files, complete with supporting documents and co of PERCS A roval Letter, and dates consistent with Pro am Info: Program Element Last Submittal Received Last Approval Date Next Due g Date In file? PP Date In file , If Applicable Headworks Analysis WA) 5/31/07 ® Yes ❑ No 7/1/08 ® Yes ❑ No 5/31/12 Industrial Waste SurveyIWS) 5/27/11 ® Yes ❑ No 6/24/11 ® Yes ❑ No 6/1/16 Sewer Use Ordinance (SUO) 4/9/07 ® Yes ❑ No 4/11/07 ® Yes ❑ No Enforcement Response Plan ERP) 7/15/09 ® Yes ❑ No 8/13/09 ® Yes ❑ No Long Term Monitoring Plan (LTMP) 1/25/07 ® Yes ❑ No 3/15/07 ® Yes ❑ No INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR I FILE REVIEW AND 1 IU INSPECTION) 29. User Name IF L Daimler Trucks (Freightliner) 2. 3. 30. IUP Number 0001 31. Does File Contain Current Permit? ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No 32. Permit Expiration Date 2013 33. Categorical Standard A lied (I.E. 40 CFR, Etc.) Or N/A 433.17 34. Does File Contain Permit Application Completed Within One Year Prior ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No 11 to Permit Issue Date? 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? a. ®Yes ❑No a. ❑Yes ❑No a. ❑Yes ❑No b. If No, is One Needed? (See Inspection Form from POTW) b. ❑Yes ❑No b. ❑Yes ❑No b. ❑Yes ❑No 37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic ❑Yes❑NoNN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Organic Management Plan (TOMP)? 38. a. Does File Contain Original Permit Review Letter from the Division? a. ®Yes ❑No a. ❑Yes ❑No a. ❑Yes ❑No b. All Issues Resolved? b.®Yes❑No❑N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A 39. During the Most Recent Semi -Annual Period, Did the POTW Complete ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No its Sampling as Required by IUP, includingflow? 40. Does File Contain POTW Sampling Chain -Of -Custody Forms? ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No 41a. During the Most Recent Semi -Annual Period, Did the SIU Complete its ®Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Sampling as Required b IUP, includingflow? 41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports ®Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A on time? 42a. For categorical lUs with Combined Wastestream Formula (CWF), does ®Yes❑No❑N/A 11 ❑Yes❑No❑N/A ❑Yes❑No❑N/A file include process/dilution flows as Required b 1UP? 42b. For categorical lUs with Production based limits, does file include ❑Yes❑NoON/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A production rates and/or flows as Required b IUP? 43a. During the Most Recent Semi -Annual Period, Did the POTW Identify NYes❑No❑NA ❑Yes❑No❑N/A ❑Yes❑No❑N/A All Limits Non -Compliance from Both POTW and SIU Sampling? 43b. During the Most Recent Semi -Annual Period, Did the POTW Identify ®Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A All Reporting Non -Compliance from SIU Sampling? 44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self- a.❑Yes®No❑N/A a.❑Yes❑No❑N/A a.❑Yes❑No❑N/A Monitoring Violations? b. Did Industry Resample and submit results to POTW Within 30 Days? b.®Yes®No❑N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A c. Did POTW resample within 30 days of knowledge of SIU limit violations from the POTW sample event? c.®Yes®No❑N/A c.❑Yes❑No❑N/A c.❑Yes❑No❑N/A 45. Duringthe Most Recent Semi -Annual Period, Was the SIU in SNC? El es ® No ❑ Yes ❑ No ❑Yes ❑ No 46. During the Most Recent Semi -Annual Period, Was Enforcement Taken ®Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A as Specified in the POTW's ERP (NOVs, Penalties, timing, tc.)? 47. Does the File Contain Penal Assessment Notices? ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 48. Does The File Contain Proof Of Penal Collection? ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 49. a. Does the File Contain Any Current Enforcement Orders? a.❑Yes❑No®N/A a.❑Yes❑No❑N/A a.❑Yes❑No❑N/A b. Is SIU in Compliance with Order? b.❑Yes❑No®N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A 50. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑ Yes ®No ❑Yes ❑ No ❑ Yes ❑ No Requested Information For You? NC DWQ Pretreatment Compliance Inspection (PCI) Form ilpdated 7/2i/07 Page 2 rTh VIEW COMMENTS: F4.application was submitted on 6/29/07. 35. The inspection was conducted on 5/18/11. 37. Daimler Trucks (Freightliner) performs the TTO Analyses. 38. The permit was approved on 10/10/08. 44. Daimler Trucks failed to notify the POTW of chromium and zinc monthly average limit violations within 24 hours in February 2012. 46 and 47. There was one violation in 2011 for oil and grease which was addressed by a NOV and resampled on 6/3/11. In February 2012 the SIU failed to notify the POTW of IUP monthly limit violations for chromium and zinc, and failing to report temperature and pH as required by the permit. The POTW sent the SIU a NOV and assessed a $500.00 civil penalty. SUMMARY AND COMMENTS: Comments: 1. Wes Bell and Donna Hood, MRO Surface Water Protection, assisted with the inspection. 2. The facility was in violation of NPDES Permit limits in April 2011, NOV-2011-LV-0281 (see PCI dated September 29, 2011). 3. The STMP detection levels need to be revised to reflect the detection levels of the analyses being used. The POTW is analyzing for both mercury method 245 and method 1631 on the effluent. In reporting the STMP mercury on the DMR, please report in ng/L for method 1631 analyses. 4. The POTW adopted the Sewer Use Ordinance on 5/15/2007. Requirements: 1. Revise the detection limits in the STMP and submit the revisions to the Division's PERCS Unit by no later than 4/30/2012. Recommendations: 1. The pretreatment program appeared to be well organized and managed. No recommendations. NOD: ❑ YES ®NO NOV: ❑ YES ® NO QNCR: ❑ YES ® NO POTW Rating: Satisfactory ® Marginal ❑ Unsatisfactory_ ❑ PCI COMPLETED BY: DATE: March 9, 2012 J h 1,4sley, Mooresville Regi n fice NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7.2510 ;7 Page 3 NCDENR North Carolina Department of Environment and Natural Resources Division of water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary The Honorable John Steele, Jr., Mayor Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Subject: Dear Mr. Mayor Steele: September 28, 2011 Pretreatment Compliance Inspection Town of Cleveland NPDES Permit No. NCO049867 Rowan County, NC Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection conducted at the subject facility on September 27, 2011 by John Lesley of this Office. . The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Mr. Lesley at (704) 663-1699. Sincerely, Robert B. Krebs Surface Water Protection Section Regional Supervisor Enclosure cc: Central Files Monti Hassan, PERCS Unit Mooresville Regional Oliice Location: 610 East Center Ave.. Suite 301 Mooresville. NC; 281. l Phone: (704) 663-1699 t. Fax: (704) 663-6040 t Customer Service: 1-877-623-6748 Internet: http:llpor al.ncdenr.org/web/wq One NorthCarolina Natlllral& An Equal. Opportnni1v `•. Affirmative Aciion li:mplover--;01"o Recvcledllo"- Post Con>umer paper NORTH CARD LIMA DIVISION OF WATER QUALITY CDE ik PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)l 1. Control Authority (POTW) Name: Town of Cleveland 2. Control Authority Representative(s): Dena Myers and Pat Phifer 3. Title(s): Consultant - Statesville Analytical Town of Cleveland - Water/Sewer Commissioner 4. Last Inspection Date: 9/28/10 Inspection Type: ® PCI ❑ Audit v� UN A N 0 v; 31 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 ® NA PCS CODING Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type N NCO049867 09/27/10 P S I (DTTA) (TYPI) (INSP) (FACC) 7. Current Number Of Significant Industrial Users (SIUs)? 1 SIUS 8 (,=cn'L Number Of Categorical Industrial Users (CIUs)? 1 CIUS 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. Enter the Higher Number of 9 or 10 0 NOIN 12. Number of SIUs With No IUP, or With an Expired IUP 0 NOCM 13. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2 Semi -Annual Periods (Total Number of SIUs in SNC) 0 PSNC 14. Number of SIUs in SNC For Re orting During Either of the Last 2 Semi -Annual Periods 0 MSNC 15. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods 0 SNPS 16. Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2 Semi-annual Periods 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? 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? 19. Which Industries have been in SNC for Limits or Reporting during SNC fa either of the Last 2 Semi -Annual Periods? Not Been Published for SNC foi Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pu 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? 21. Are Any Permits Or Civil Penalties Currently Under Adjudication? If Yes, Which Ones? ® YES ❑ NO BOD: NOV-2011-LV-0281 ❑ YES ®NO Limits: NA Reporting: NA )lished: NA NA ❑ 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 2.5. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ® YES ❑ NO 26. If NO to 23 - 26, list violations: 27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO If yes, which ones? Eliminated: Added: NC DWQ Pretreatment Compliance Inspection (PCI) Form I pdat(.,ci W)5/07 Page 1 V RETREATMENT PROGRAiM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element in les, complete with supwrtina documents and coot/ of PERCS Annrnval Letter and dates consistent with Prnornm Infn Program Element Last Submittal Received Date In file? Last Approval Date In file Date Next Due, If Applicable Headworks Analysis (HWA) 5/31/07 ® Yes ❑ No 7/1/08 ® Yes ❑ No 5/31/12 industrial Waste Survey IWS) 5/27/11 ® Yes ❑ No 6/24/11 ® Yes ❑ No .6/1/16 Sewer Use Ordinance (SUO) 4/9/07 ® Yes ❑ No 4/11/07 ® Yes ❑ No Enforcement Response Plan (ERP) 7/15/09 ® Yes ❑ No 8/13/09 ® Yes ❑ No Long Term Monitoring Plan (LTMP) 1/25/07 ®Yes ❑ No 3/15/07 ® Yes ❑ No INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND I IU INSPECTION) 29. User Name 1. Daimler Trucks 2. 3. 30. IUP Number 0001 31. Does File Contain Current Permit? ® Yes ❑ No 11 ❑ Yes ❑ No ❑ Yes ❑ No 32. Permit Expiration Date 6/30/13 33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 433.17 34. Does File Contain Permit Application Completed Within One Year Prior ® Yes ❑ No ❑Yes ❑ No ❑ Yes ❑ No to Permit Issue Date? 35. Does File Contain an Inspection Completed Within Last Calendar Year? L X Yes LJ No L Lf Yes LJ No I L] Yes L] No 36. a. Does the File Contain a Slug/Spill Control Plan? a. NYes ❑No a. ❑Yes []NoF�EYes ❑No b. If No, is One Needed? (See Ins ection Form from POTW) b. ❑Yes ❑No b. ❑Yes ❑No Yes ❑No 37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic ❑Yes❑NoEN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Organic Management Plan (TOMP)? 38. a. Does File Contain Original Permit Review Letter from the Division? a. NYes ❑No a. ❑Yes ❑No a. ❑Yes ❑No b. All Issues Resolved? b.®Yes❑No❑N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A 39. During the Most Recent Semi -Annual Period, Did the POTW Complete ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No its Sampling as Required by IUP, including flow? 40. Does File Contain POTW Sampling Chain -Of -Custody Forms? ® Yes ❑ N7ol ❑ Yes ❑ —N—oll ❑ Yes ❑ No 41a. During the Most Recent Semi -Annual Period, Did the SIU Complete its ®Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Sampling as Required by IUP, including flow? 41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports ®Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A on time? 42a. For categorical IUs with Combined Wastestream Formula (CWF), does file include process/dilution flows as Required by IUP? 42b. For categorical IUs with Production based limits, does file include production rates and/or flows as Required by IUP? 43a. During the Most Recent Seini-Aruival Period, Did the POTW Identify All Limits Non -Compliance from Both POTW and SIU Sampling? 43b. During the Most Recent Semi -Annual Period, Did the POTW Identify All Reporting Non -Compliance from SIU Sampling? 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. Did POTW resample within 30 days of knowledge of SIU limit violations from the POTW sample event? 45. During the Most Recent Semi -Annual Period, Was the SIU in SNC? 46. During the Most Recent Semi -Annual Period, Was Enforcement Taken as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)? 47. Does the File Contain Penalty Assessment Notices? 48. Does The File Contain Proof Of Penalty Collection? 49. a. Does the File Contain Any Current Enforcement Orders? b. Is SIU in Compliance with Order? 50. - Did the POTW Representative Have Difficulty in Obtaining Any of This Requested Information For You? ®Yes❑No❑N/A 11 ❑Yes❑No❑N/A 11 ❑Yes❑No❑N/A ❑Yes❑NoEN/A 11 ❑Yes❑No❑N/A 11 ❑Yes❑No❑N/A ®Yes❑No❑NA ®Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A a.®Yes❑No❑N/A a.❑Yes❑NoDN/A a.❑Yes❑No❑N/A b.®Yes❑No❑N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A c.EYes❑No❑N/A c.❑Yes❑No❑N/A c.❑Yes❑No❑N/A ❑ Yes ®No I ❑ Yes ❑ No ❑ Yes ❑ No ®Yes❑No❑N/A 11 ❑Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑NoEN/A II ❑Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑NoEN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A a.❑Yes❑NoEN/A .❑Yes❑No❑N/A Fb.oYesoNoON/A a.❑Yes❑No❑N/A b.❑Yes❑NoEN/A b.❑Yes❑No❑N/A ❑ Yes ®No 17Ye7 No ❑Yes ❑ No NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7:'•2-5'07 Page 2 FILE REVIEW COMMENTS: 1. The IUP Application was signed on 6/29/07. 2. The SIU Inspection was performed on 5/18/11. 3. Daimler Trucks was issued a Notice of Violation for oil/grease on 6/13/11. 4. Daimler Trucks failed to give the notice of contact person change. The Town is preparing a Notice of Violation for failure to notify. SUMMARY AND COMMENTS: Comments: 1. The BOD non -compliance (April 2011) was associated with an issue in the WWTP and was not related to the SIU. 2. The Sewer Use Ordinance was adopted on 5/15/07. Requirements: See the Program Elements Review Section of this report. Recommendations: NOD: ❑ YES ®NO NOV: ❑ YES ®NO QNCR: ❑ YES ® NO POTW Rating: Satisfactory ® Marginal ❑ Unsatisfactory_ ❑ PCI COMPLETED BY: '_ l>4 v� �a— ^� DATE: September 28, 2011 John Lesley, Mooresville Regional Office NC DWQ Pretreatment Compliance Inspection (PCI) Form 111pcizited T,25/07 Page 3 4 r ILE CDEN North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director Dee Freeman Secretary April 25, 2011 The Honorable John Steele, Jr. Mayor Town of Cleveland Post Office Box 429 Cleveland, NC 27013 Subject: PAR Review Town of Cleveland NPDES Permit No. NCO049867 Rowan County, NC Dear Mayor Steele: Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR) for the reporting period of January through December 2010. Based on the review, the POTW completed the PAR in accordance with 15A NCAC 2H .0908(b) requirements and guidelines set forth in Comprehensive Guidance for North Carolina Pretreatment Programs. The next PAR will be due March 1, 2012. If you have any questions concerning your PAR, please do not hesitate to contact me at (704) 663-1699 or by email atjohn.lesley@ncdenr.gov. Sincerely Lesley Mooresville Regional Office Contact Cc: Monti Hassan, PERCS Unit Mooresville Regional Office One Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 NorthCarolina Phone: (704) 663-1699 \ Fax: (704) 663-6040 \ Customer Service: 1-877-623-6748 Nato -al4il Internet: hfp:llportal.ncdenr.orglweb/wq An Equal Opportunity \ Affirmative Action Emplover — 50% Recycled!10% Post Consumer paper kaA-� NC®NR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director March 30, 2010 The Honorable John I. Steele, Jr. Mayor Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Subject: Pretreatment Annual Report Town of Cleveland NPDES Permit No. NCO049867 Rowan County, NC Dear Mayor Steele: Dee Freeman Secretary Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR) for the reporting period of January through December 2009. Based on the review, it appears that the POTW completed the PAR in accordance with 15A NCAC 2H .0908(b) requirements and guidelines set forth in Comprehensive Guidance for North Carolina Pretreatment Programs for modified pretreatment programs. The next PAR will be due March 1, 2011. If you have any questions concerning your PAR, please do not hesitate to contact me at (704) 663-1699. Sincerely, hn Lesley Mooresville Regional Office Contact Cc: Monti Hassan, PERCS Unit Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-1699 \ Fax: (704) 663-6040 \ Customer Service: 1-877-623-6748 Internet: hftp://por al.ncdenr.org/web/wq One NorthCarolina An Equal Opportunity \ Affirmative Action Employer— 50% Recycled/l0% Post Consumer paper Beverly Eaves Perdue Governor FILE ,p WDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Director September 29, 2010 The Honorable John Steele, Jr., Mayor Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Subject: Pretreatment Compliance Inspection Town of Cleveland NPDES Permit No. NCO049867 Rowan County, NC Dear Mr. Mayor Steele: Dee Freeman Secretary Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection conducted at the subject facility on September 28, 2010 by John Lesley of this Office. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Mr. Lesley at (704) 663-1699. Sincerely, 1 --Robert B. Krebs Surface Water Protection Section Regional Supervisor Enclosure cc: Central Files Monti Hassan, PERCS Unit Mooresville Re.-ional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-1699 \ Fax: (704) 663-6040 \ Customer Service: 1-877-623-6748 Internet: hfp:llportal.ncdenr.orghveb/wq Nne orthCarolina Natl r"411 An Fminl nnnnrttin ity \ Affirmative Action Emolover — 50% Recvcled/10% Post Consumer paper N"RTH C'AROIANA DIVISION OF WATER OUALITY NC®ENR PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT BACKGROUND INFORMATION [Complete Prior To PCI• Review Program Info Database Sheet(s)] 1. Control Authority (POTW) Name: Town of Cleveland 2. Control Authority Representative(s): Dena Myers, Tracy Moore 3. Title(s): Consultants, Statesville Analytical 4. Last Inspection Date: 4/23/09 Inspection Type: ® PCI ❑ Audit o� F WarF9Qc r o 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 ® NA PCS CODING Trans.Code Main Program Permit Number MNI/DD/YY Inspec.Type Inspector Fac. Type N NCO049867 09/28/10 P S 1 mTT A ) (TYPT) (INSP) (FACC) 7. Current Number Of Significant Industrial Users (SIUs)? 8. Current Number Of Categorical Industrial Users (CIUs)? F1 1 SIDS CIUS 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. Enter the Higher Number of 9 or 10 0 NOIN 12. Number of SIUs With No IUP, or With an Expired IUP 0 NOCM 13. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2 Semi -Annual Periods (Total Number of SIUs in SNC) 14. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods 0 I- ::]:::� PSNC MSNC 15. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods L 0 SNPS 16. Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2 Semi-annual Periods 11 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? 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? 19. Which Industries -have been in SNC for Limits or Reporting during SNC foe either of the Last 2 Semi -Annual Periods? Not Been Published for SNC foi Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pu 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? 21. Are Any Permits Or Civil Penalties Currently Under Adjudication? If Yes, Which Ones? ® YES ❑ NO TRC Limit NOV-2010-LV-0276 ❑ YES ® NO Limits: None Reporting: None blished: None None ❑ 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 26. If NO to 23 - 26, list violations: 27., Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO If yes, which ones? Eliminated: Added: NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page I V28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element in their file.. comnlete with sunnorting documents and coov of PERCS ADDroval Letter, and dates consistent with Program Info: Program Element Last Submittal Received Date In file? Last Approval Date In file Date Next Due, If Applicable Headworks Analysis (HWA) 5/31/07 ® Yes ❑ No 7/1/08 ® Yes ❑ No 5/31/12 Industrial Waste Survey IWS) 7/3/08 ® Yes ❑ No 9/30/08 ® Yes ❑ No 6/1/11 Sewer Use Ordinance (SUO) 4/9/07 ® Yes ❑ No 4/11/07 ® Yes ❑ No Enforcement Response Plan (ERP) 7/15/09 ® Yes ❑ No 8/13/09 ® Yes ElNo Long Term Monitoring Plan (LTMP) 1/25/07 ® Yes ElNo 3/15/07 ® Yes ❑ No INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR I FILE REVIEW AND I IU INSPECTION) 29. User Name 1. Freightliner 2. 3• 30. IUP Number 0001 31. Does File Contain Current Permit? ® Yes ❑ No ❑ Yes ❑ No -IF ❑ Yes ❑ No 32. Permit Expiration Date 6/30/13 33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 433.17 34. Does File Contain Permit Application Completed Within One Year Prior ® Yes ❑ No IF�� ❑ No ❑ Yes ElNo to Permit Issue Date? 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? a. ®Yes EIN 7 07 a. ❑Yes ❑No j a. ❑Yes ❑No b. if No, is One Needed? (See Inspection Form from POTW) b. ❑Yes ❑No 11 b. ❑Yes ❑No b. ❑Yes ❑No 37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic ❑Yes❑NoEN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Organic Management Plan (TOMP)? 38. a. Does File Contain Original Permit Review Letter from the Division? a. NYes ❑No a. ❑Yes ❑No IFa.. ❑Yes ❑No b. All Issues Resolved? b.®Yes❑No❑N/A b.❑Yes❑No❑N/A I b.❑Yes❑No❑N/A 39. During the Most Recent Semi -Annual Period, Did the POTW Complete ® Yes ❑ No ❑ Yes ❑ T4 ❑ Yes ❑ No its Sampling as Required by IUP, including flow? 40. Does File Contain POTW Sampling Chain -Of -Custody Forms? ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No 41a. During the Most Recent Semi -Annual Period, Did the SIU Complete its ®Yes❑No❑N/A �[0YesE1No[1N!/flj ❑Yes❑No❑N/A Sampling as Required by IUP, inclu ing flow? - 41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports ®Yes❑No❑N/A ❑Yes❑No❑N/A [ 1 ❑Yes❑No❑N/A on time? 42a. For categorical IUs with Combined Wastestream Formula (CWF), does ®Yes❑No❑N/A I ❑Yes❑No❑N/A ❑Yes❑No❑N/A file includeprocess/dilution flows as Required by IUP? 42b. For categorical IUs with Production based limits, does file include ❑Yes❑NoEN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A production rates and/or flows as Required by IUP? 43a. During the Most Recent Semi -Annual Period, Did the POTW Identify ®Z es❑No❑NA ❑Yes❑No❑N/A ❑Yes❑No❑N/A All Limits Non -Compliance from Both POTW and SIU Sampling? 43b. During the Most Recent Semi -Annual Period, Did the POTW Identify ❑Yes❑NoEN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A All Reporting Non -Compliance from SIU Sampling? 44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self- a.❑Yes❑No®N/A a.❑Yes❑No❑N/A a.❑Yes❑No❑N/A Monitoring Violations? b. Did Industry Resample and submit results to POTW Within 30 Days? b.❑Yes❑No®N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A c. Did POTW resample within 30 days of knowledge of SIU limit c.❑Yes❑No®N/A c.❑Yes❑No❑N/A c.❑Yes❑No❑N/A violations from the POTW sample event? 45. During the Most Recent Semi-Amtual Period, Was the SIU in SNC? ❑ Yes ® No ❑ Yes ❑ No 11 ❑ Yes ❑ No 46. During the Most Recent Semi -Annual Period, Was Enforcement Taken EYes❑No❑N/A ❑Yes❑No❑N/A 11 ❑Yes❑No❑N/A as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)? 47. Does the File Contain Penalty Assessment Notices? ❑Yes❑NoEN/A ❑Yes❑No❑N/A 11 ❑Yes❑No❑N/A 48. Does The File Contain Proof Of Penalty Collection? ❑Yes❑NoEN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 49. a. Does the File Contain Any Current Enforcement Orders? a.❑Yes❑No®N/A a.❑Yes❑No❑N/A I a.❑Yes❑No❑N/A b. Is SIU in Compliance with Order? b.❑Yes❑No®N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A 50. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑ Yes ® No ❑ Yes ❑ No ❑ Yes ❑ No Requested Information For You? NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2 FILE REVIEW COMMENTS: 31. The POTW representative did not attend the inspection meeting. Files were provided by the POTW's consultant. 34. The IUP Application was completed on 6/29/07. 35. The SIU Inspection was completed on 8/25/10. 36. The SIU updated the Spill and Slug Control Plan on 8/25/10. 37. Feightliner conducts the TTO analyses. 38. The IUP was approved on 10/10/08. 11 41b. The SIU was reporting less than results with an "X". The POTW required that the IDMRs be amended to show the "<value". 46. Freightliner was noncompliant for chromium in February 2010. .A Notice of Violation was sent on 4/23/10. SUMMARY AND COMMENTS: Comments: Statesville Analytical acts as the POTW's consultant and performs all phases of the program (sampling, inspections, compliance judgment, preparation of program elements, etc.). Notices of Violation are signed by the Mayor. The Pretreatment Program is well managed. Requirements: Be advised that the Town of Cleveland (the Control Authority) must be represented at Compliance Inspections to properly address questions the Division may have regarding Town policy in addressing various compliance issues or problems with Industrial Users. Recommendations: NOD: ❑ YES ®NO NOV: ❑ YES ® NO QNCR: [:]YES ® NO POTW Rating: Satisfactory ® Marginal ❑ Unsatisfactory_ ❑ PCI COMPLETED BY: n Lksley, Mooresville Regional TE: September 29, 2010 NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3 �W FgC®ENR North Carolina Department of ]Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director - Dee Freeman Secretary April 27, 2009 Mr. Danny Gabriel, Mayor Pro Tern Industrial Pretreatment Program Contact Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Subject: Pretreatment Annual Report Town of Cleveland NPDES Permit No. NCO049867 Rowan County, NC Dear Mr. Gabriel: Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR) for the reporting period of January through December 2008. Based on the review, it appears that the POTW completed the PAR in accordance with 15A NCAC 2H .0908(b) requirements and guidelines set forth in Comprehensive Guidance for North Carolina Pretreatment Programs for modified pretreatment programs. The next PAR will be due March 1, 2010. Be advised that all future submittals of the PAR must include a Narrative Summaryoof the compliance activities of all SIUs for the vear. Pretreatment Proiaram Summary (PPS) pate, and a Sisnificant Non -Compliance Report (SNCR) page. If there is no SNC for the year, then include the SNCR page and write "No SNC" on it. If you have any questions concerning your PAR, please do not hesitate to contact me at (704) 663-1699. Since ely, C� ohn Lesley Mooresville Regional Office Contact Cc: Monti Hassan, PERCS Unit Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-1699 \ Fax: (704) 663-6040 \ Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org Nne oirthCarolina Naturallll An Equal Opportunity \ Affirmative Action Employer — 50% Recycled/10% Post Consumer paper Beverly Eaves Perdue Governor NC®EN North Carolina Department of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Director April 24, 2009 The Honorable James Brown, Mayor Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Subject: Pretreatment Compliance Inspection Town of Cleveland NPDES Permit No. NCO049867 Rowan County, NC Dear Mr. Mayor Brown: Dee Freeman Secretary Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection conducted at the subject facility on April 23, 2009 by Rob Krebs and John Lesley of this Office. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Mr. Lesley or me at (704) 663-1699. Sincerely, ert B. Krebs �7 Surface Water Protection Section Regional Supervisor Enclosure cc: Central Files Monti Hassan, PERCS Unit Mooresville Regional Office One Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 NorthCarolliina Phone: (704) 663-1699 \ Fax: (704) 663-6040 \ Customer Service: 1-877-623-6748 Natltral& Internet: www.ncwaterquality.org . — _,,.___ �.__:...I .cc___a:.._ n_.:--r_..,,..i..,,... —/ D—....i—m no/ 0—frnn .—r nnnpr Aian NORTH CAROLINA DIVISION OF WATER QUALITY NCDENR PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT BACKGROUND INFORMATION [Complete Prior To PCI• Review Program Info Database Sheet(s)] 1. Control Authority (POTW) Name: Town of Cleveland W ATfRQ 2. Control Authority Representative(s): Danny Gabriel, Dena Myers, Tracy Moore 3. Title(s): Cleveland Mayor Pro-Tem and Statesville Analytical Pretreatment Program Consultants 4. Last Inspection Date: 04/08/08 Inspection Type: ❑ 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 ®NA PCS CODING Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type N NCO049867 04/23/2008 P S 1 (DTTA) (TYPI) (INSP) (FACC) 7. Current Number Of Significant Industrial Users (SIUs)? 1 SIUS 8. Current Number Of Categorical Industrial Users (CIUs)? 1 CIUS 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. Enter the Higher Number of 9 or 10 0 NOIN 12. Number of SIUs With No IUP, or With an Expired IUP 0 NOCM 13. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2 Semi -Annual Periods (Total Number of SIUs in SNC) 0 PSNC 14. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods 0 MSNC 15. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods 0 SNPS 16. Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2 Semi-annual Periods 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? 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? 19. Which Industries have been in SNC for Limits or Reporting during SNC either of the Last 2 Semi -Annual Periods? Not Been Published for SNC Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not l 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? 21. Are Any Permits Or Civil Penalties Currently Under Adjudication? If Yes, Which Ones? ® YES ❑ NO 7/08 NOV-2008-LV-0537 —fecal col. 11/08 NOV-2009-LV-0088 — NH3N ❑ YES ® NO 'or Limits: None or Reporting: None 'ublished: None NA ❑ YES ® NO STMP FILE REVIEW: 22. Is 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 STMP Data Maintained in a Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO 25. All STMP effluent data reported on Discharge Monitoring Report? ® YES ❑ NO 26. If NO to 23 - 26, list violations: 27. Should any Pollutants of Concern be Eliminated from or Added to STMP? ❑ YES ® NO If yes, which ones? Eliminated: Added: NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 1 28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element in their files_ comnlete with sunnortine documents and copv 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) 5/31/07 ® Yes ❑ No 7/1/08 ® Yes ❑ No 5/31/12 Industrial Waste Survey (IWS) 6/25/08 ® Yes ❑ No 9/30/08 ® Yes ❑ No 6/1/11 Sewer Use Ordinance SUO) 4/9/07 ® Yes ❑ No 4/1/07 ® Yes ❑ No Enforcement Response Plan (ERP) 12/1/94 ® Yes ❑ No 12/28/94 ® Yes ❑ No see comments Short Term Monitoring Plan (LTMP) 1/18/07 ® Yes ❑ No 3/15/07 ® Yes ❑ No INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION) 29. User Name IF 1. Freightliner 2. 3. 30. IUP Number 0001 31. Does File Contain Current Permit? ® Yes El No ❑ Yes ❑ No ❑Yes ❑ No 32. Permit Expiration Date 6/30/13 33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 433.17 34. Does File Contain Permit Application Completed Within One Year Prior ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No to Permit Issue Date? 35. Does File Contain an Inspection Completed Within Last Calendar Year? ® Yes ❑ No 11 ❑ Yes ❑ K—oll ❑ Yes ❑ No 36. a. Does the File Contain a Slug/Spill Control Plan? F a. ®Yes ❑No a. []Yes [:]No 11 a. ❑Yes ❑No b. If No, is One Needed? (See Inspection Form from POTW) b. ❑Yes No b. ❑Yes ❑No b. ❑Yes ❑No 37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic ❑Yes❑NoSN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Organic Management Plan (TOMP)? 38. a. Does File Contain Original Permit Review Letter from the Division? a. NYes ❑No . ❑Yes ❑No �Fa. Ft' ❑Yes ❑No b. All Issues Resolved? b.®Yes❑No❑N/A .❑Yes❑No❑N/A I b.❑Yes❑No❑N/A 39. During the Most Recent Semi -Annual Period, Did the POTW Complete ®Yes ❑ No ❑ Yes ❑ No F ❑Yes ElNo its Sampling as Required by IUP, including flow? - 40. Does File Contain POTW Sampling Chain -Of -Custody Forms? I ® Yes ❑ No [:]Yes ❑ Noll ❑ Yes ❑ No 41 a. During the Most Recent Semi -Annual Period, Did the SIU Complete its ®Yes❑No❑N/A ❑Yes❑No❑N/A F ❑Yes❑No❑N/A Sampling as Required by IUP, including flow? 41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports SYes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A on time? 42a. For categorical IUs with Combined Wastestream Formula (CWF), does SYes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A file includeprocess/dilution flows as Required by IUP? 42b. For categorical IUs with Production based limits, does file include ❑Yes❑NoEN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A production rates and/or flows as Required by IUP? 43a. During the Most Recent Semi -Annual Period, Did the POTW Identify ®Yes❑No❑NA ❑Yes❑No❑N/A ❑Yes❑No❑N/A All Limits Non-Com liance from Both POTW and SIU Sampling? 43b. During the Most Recent Semi -Annual Period, Did the POTW Identify ❑Yes❑NoSN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A All Re ortin Non -Compliance from SIU Sampling? 44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self- a.®Yes❑No❑N/A a.❑Yes❑No❑N/A a.❑Yes❑No❑N/A Monitoring Violations? b. Did Industry Resample and submit results to POTW Within 30 Days? b.®Yes❑No❑N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A c. Did POTW resample within 30 days of knowledge of SIU limit c.❑Yes❑No❑N/A c.❑Yes❑No❑N/A c.❑Yes❑No❑N/A violations from the POTW sample event? 45. During the Most Recent Semi -Annual Period, Was the SIU in SNC? I ❑ Yes ® No ❑ Yes ❑ No 11 ❑ Yes ❑ No 46. During the Most Recent Semi -Annual Period, Was Enforcement Taken SYes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)? 47. Does the File Contain Penalty Assessment Notices? ❑Yes❑NoSN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 48. Does The File Contain Proof Of Penalty Collection? ❑Yes❑NoSN/A ❑Yes❑No❑N/A ❑Yes❑No❑NIA 49. a. Does the File Contain Any Current Enforcement Orders? a.❑Yes❑No®N/A I a.❑Yes❑No❑N/A a.❑Yes❑No❑N/A b. Is SIU in Compliance with Order? b.❑Yes❑No®N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A 50. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑Yes g No ❑ Yes ❑ No ❑ Yes ❑ No Requested Information For You? NC DWO Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2 FILE REVIEW COMMENTS: 34: The IUP Application was completed on 6/29/07. 35: The SIU Inspection was completed on 12/4/08. 37: Freightliner performs the TTO analyses. 43: Freightliner violated the limits for zinc on 2/13/08 and 12/3/08. Notices of Violation were sent for the violations. The SIU had no reporting violations in 2008. SUMMARY AND COMMENTS: Comments: The Enforcement Response Plan was revised on 5/29/02 to reflect a maximum civil penalty of $25,000 per day. The Central Office was copied on the revision, but, no approval has been documented. NPDES Permit violations: Fecal Coliform 7/08 and Ammonia Nitrogen Violation 11/08. Ammonia Nitrogen violation resulted from mechanical problems at WWTP. Requirements: 1. See Program Elements Review Section of this report. 2. No flow value was reported on 5/31/2008. Please submit an amended DMR that includes the flow value and revised average by no later than May 4, 2009. Recommendations: The Town of Cleveland Industrial Pretreatment Program is well organized and managed. Keep up the good work. NOD: [:]YES ® NO NOV: [:]YES ® NO QNCR: ❑ YES ® NO POTW Rating: Satisfactory ® Marginal ❑ Unsatisfactory_ ❑ JPCI COMPLETED BY -� DATE: April 24, 2009 Jo n L sley, Mooresville Regiona Of ce NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25!07 Page 3 \OF WATF9n O JG cis 1� r April 11, 2008 The Honorable James Brown, Mayor Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Michael F. Easley, Governor William G_ Ross Jr_, Secretary North Carolina Department of Environment and Natural Resources Coleen Sullins_ Director Division of Water Quality Subject: Pretreatment Audit Inspection Town of Cleveland NPDES Permit No. NCO049867 Rowan County, NC Dear Mr. Mayor Brown: Enclosed is a copy of the Pretreatment Audit Report for the inspection conducted at the subject facility on April 8, 2008 John Lesley of this Office. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Mr. Lesley or me at (704) 663-1699. Sincerely, -d obert B. Krebs C Surface Water Protection Section Regional Supervisor Enclosure cc: Central Files Monti Hassan, PERCS Unit Rowan County Health Department r�°1e cazotina 1Vnhir�//ri N. C. Division of Water Quality, Mooresville Regional Office, 610 E_ Center Ave_ Suite 301, Mooresville NC 28115 (704) 663-1699 Customer Service 1-877-623-6748 . —�— NORTH CAROLINA DIVISION OF WATER QUALITY P!CDE!VR PRETREATMENT AUDIT REPORT ' DadWound Information: - - 1. Control Authority (POTW) Name: Town of Cleveland 2. Control Authority Representative(s): Danny Gabriel, Dena Myers, Tracy Moore 3. Title(s): Cleveland Mayor Pro Tem and Statesville Analytical Consultants 4. Address of POTW: Mailing Post Office Box 429 City Cleveland, NC Zip Code 27013 Phone Number 704-278-4777 Fax Number 704-278-0078 E-Mail Consultant: Statesville Analytical Phone Number: 704- 5. Audit Date 04/08/2008 6. Last Inspection Date: 11/08/2006 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. 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 PCS (WENDB)CodinQ: Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type I I N I C I 0 I 0 14 19 18 1 6 17 I L 04 108 1 08I I_ G I ICI I_ I I (DTIA) (TYPI) (INSP) (FACC) 10. Current Number of Significant Industrial Users (SILTS)? 1 SIUS 11. Current Number of Categorical Industrial Users (CIUS)? _ _ 1 CIUS 12. Number of SIUs Not Inspected by POTW in Last Calendar Year? _ T_ _�... _ __.._ _._ 0 13. Number of SIUs Not Sampled. y POTW in Last Calendar Year? 0 14. Enter higher Number of 12 or 13 0 NOIN 15. Number of SIUs with No ", or with an Expired IUP _ 0 NOCM 16. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of Last 2 0 PSNC Semi -Annual Periods (Total Number of SIUs in SNC) 17. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods _ 0 MSNC 18. Number of SlUs in SNC for Limits Violations During Either. of Last, 2 Semi -Annual Periods 0 SNPS 19. Number of SIUs in SNC for Both Reporting and Limits Violations During Either of Last 2 0 Semi -Annual Periods 20. Number of SIUs in SNC for Self -Monitoring Requirements that were Not Inspected or Sampled 0 SNIN NC DWQ Pretreatment Audit Form Revised: July 25, 2007 Page 1 0 Program Element Last Submittal Date In file? Last Approval Date In file Date Next Due, If Applicable Headworks Analysis (HWA) 4/7/08 ® Yes ❑ No 3/3/04 ® Yes ❑ No In Review Industrial Waste Survey (IWS) 6/8/05 ® Yes ❑ No 3/27/00 ® Yes ❑ No In Review Sewer Use Ordinance (SUO) 4/9/07 ® Yes ❑ No 4/11107 ® Yes ❑ No Enforcement Response Plan (ERP) 12/1/94 ® Yes ❑ No 12/28/94 Yes ❑ No Long Term Monitoring Plan (LTMT)' 1/25/07 ® Yes ❑ No 3/15/07 ® Yes ❑ No -_ Legal Authority (Sewer Use Ordinance-SUO) 22. 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. 23. If yes to #22, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑ Yes ❑ No ® NA A copy, if not already submitted, should be sent to Division. 24. If yes to #22, Have you had any trouble working with these towns or districts? ❑ Yes ❑ No ® NA If yes, Explain. 25. Date of Last SUO Adoption by Local Council 5/15/2007 26. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No If yes, Explain. Enforcement (Enforcement Response Plan-ERP) 27. Did you send a copy of the ERP to your industries? ® Yes ❑ No If no, POTW must send copy within 30 days. 28. 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. 29. List Industries under a Schedule or Order and Type of Schedule or Order None Resources 30. 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 Access to POTW Vehicles for Sampling, Inspections, and ®S ❑M ❑U Emergencies 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 Staff Training (i.e. Annual and Regional Workshops, Etc.) ®S ❑M ❑U Computer Equipment (Hardware and Software) ®S ❑M ❑U NC DWQ Pretreatment Audit Form Revised: July 25, 2007 Page 2 - - -- r -a -- ..... - -- -,- Explain Yes or No. Statesville Analytical is on contract to administer the program. 32. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. Direct billing of costs to the SW. Public Perception/ Participation: 33. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)? ® Yes ❑ No If yes, Explain. Reduction in manufacturing at the SIU 34. 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? Make an apointment with the Town for file review. 35. 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?. Maintain confidential Tile in separate locked file cabinet. 36. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No 37. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No 38. Were all industries in SNC published in the last notice? ❑ Yes ❑ No ®NA Permitting (Industrial Waste Survey-IWS): 39a... How does the POTW become aware of new or changed Users? Continuous IWS, IWS forms are filled out at Town Hall prior to utility services being initiated. 39b. 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 W WTP and therefore require a new permit or a permit revision? (Who is an SIU?) IWS information, site visits. 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) NA 43. How does the POTW allocate its loading to industries? Mark all that apply ❑ Uniform Limits 0 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 0 No If yes, What parameters are over allocated? 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 10% 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) NPDES Permit pollutants of concern and categorical parameters. 49. How does the POTW decide what. the monitoring frequency should be for the various pollutants in industry permits ? Explain. Set monthly monitoring requirement based on historical data. NC DWQ Pretreatment Audit Form Revised: July 25, 2007 Page 3 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, reporting requirements, and permit conditions, as well as for SNC. SNC by means of the compliance judgement worksheet, late reporting is given a Notice of Violation, permit condition violations may be given a NOV. Reporting and Permit Condition noncompliance could also result in fines and SNC designation depending on severity of violation. 52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No If no, does the POTW form include all DWQ 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? Potential to impact WWTP or cause worker health and safety issues. 55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? Up to date contact information, chemicals, storage areas, housekeeping practices, and spill clean up procedures clearly indentified. 56. How does the POTW decide where the sample point for an S1U should be located? Sampling points include inside process only wastestreams, and an outside main sampling point that includes all wastewater discharged from the SIU. 57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SILT 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. Written SOP for sampling and meter calibration. 58. Who performs sample analysis for the POTW for Metals Statesville Analytical Conventional Parameters Statesville Analytical Organics Pace Laboratories 59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples. Commercial lab Chain of Custody forms are used for all sampling. Long/Short Term Monitoring Plan (L/STNIP) 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 DWQ 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: 61. Do you complete your own headworks analysis (HWA) ? ❑ Yes ® No If no, Who completes your HWA? Statesville Analytica Phone 704 872--4697 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 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. No need NC DWQ Pretreatment Audit Form Revised: July 25, 2007 Page 4 65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No INDUSTRIAL USER PERMIT FILE REVIEW: 66. User Name 1. Freightliner 2. 1 3. 67. IUP Number 0001 68. Does File Contain Current Permit? N Yes ❑ No 11 ❑ Yes 0. No 11 ❑ Yes ❑ No 69. Permit Expiration Date 12/31f2007 70. Categorical Standard Applied I.E. 40 CFR, Etc.) Or N/A 433 71. Does File Contain Permit Application Completed Within One Year Prior ZYes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No to Permit Issue Date? 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? a. ®Yes ❑No a. ❑Yes ❑No a. pYes ❑No b. If No, is One Needed? See Inspection Form from PO b. ❑Yes ❑No b. ❑Yes ❑No b. ❑Yes ❑No 74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic ❑Yes❑NoON/A ❑Yes❑No❑N/A 11 ❑Yes❑No❑N/A Organic Management Plan (TOMP)? 75. a. Does File Contain Original Permit Review Letter from Division? a. ®Yes ❑No a. pYes ❑No a. pYes ❑No b. All Issues Resolved? b.®Yes❑No❑N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A 76. During Most Recent Semi -Annual Period, Did POTW Complete its N Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No Sampling as Required by IUP, includin Flow? 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 0Yes[1No0N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Sampling as Required by IUP, including Flow? 79. During Most Recent Semi -Annual Period, Did SIU submit all reports on SYes❑No❑N/A ❑Yes❑No❑N/A pYes❑No❑N/A time? 80a. For categorical [Us with Combined Wastestream Formula (CWF), does SYes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A file includeprocess/dilution flows as Required by IUP? 80b. For categorical IUs with Production based limits, does file include ❑Yes❑NoSN/A pYes❑No❑N/A ❑Yes❑No❑N/A production rates and/or flows as Required by IUP? 81. During Most Recent Semi -Annual Period, Did POTW Identify All ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No Limits Non -Compliance from Both POTW and SIU Sam lin . 82. During Most Recent Semi -Annual Period, Did POTW Identify All SYes❑No❑N/A pYes❑No❑NIA ❑Yes❑No❑N/A Re ortin Non-Com liance from SIU Sampling? 83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self- a.®Yes❑NoON/A a.❑Yes❑No❑N/A a.❑Yes❑No❑N/A Monitoring Violations? b. Did Industry Resample and submit results to POTW within 30 Days? baYes❑No❑N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A c. If applicable, did POTW reample and obtain results within 30 days of c ❑Yes❑No®N/A c.❑Yes❑No❑N/A c.OYes❑No❑N/A becomingaware of SILT limit violations in the POTW's sampling of SIU? 84. DuringMost Recent Semi -Annual Period, Was SIU in SNC? El Yes N No ❑ Yes No Yes [I No] 85. During Most Recent Semi -Annual Period, Was Enforcement Taken as SYes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A Specified in POTW's ERP (NOVs, Penalties, timing, etc.)? 86. Does File Contain Penalty Assessment Notices? ❑Yes❑NoSN/A ❑Yes❑No❑N/A pYes❑No❑N/A 87. Does File Contain Proof Of Penalty Collection? ❑Yes❑NoSN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 88. a. Does File Contain Any Current Enforcement Orders? a.❑Yes❑No®N/A amYes❑No❑N/A a.❑Yes❑No❑N/A b. Is SIU in Compliance with Order? b.❑Yes❑No®N/A b.❑Yesmo❑N/A b.❑Yes❑No❑N/A 89. Did POTW Representative Have Difficulty in Obtaining Any Requested ❑ Yes N No ❑ Yes ❑ No ❑ Yes ❑ No Information For You? FILE REVIEW COMMENTS: 69: The IUP has expired, but the SILT has been notified by the POTW to continue under the conditions of the expired permit. 72: The SIU inspection was conducted on 12/20/2007. 74: Freightliner conducts TTO analysis. 83: The SIU is required to sample within 30 days of POTW sampling event showing noncompliance. The SIU has monthly monitoring requirements. NC DWQ Pretreatment Audit Form Revised: July 25, 2007 Page 5 Trans.Code Main Program Permit Number MM/DD/YY Inspection type Inspector Facility Type FN N I C 10 10 14 19 1 8 6 7 104 08 08 UO -s-1 2❑ (DTIA) (TYPI) QNSP) (FACC) 1. Industry Inspected: Freightlinger 2. Industry Address: 11550 Statesville Boulevard, PO Box 399, Cleveland, NC 27013 3. Type of Industry/Product: Heavy Trucks 4. Industry Contact: Bryon Miller Title: Supervisor Env. Engineering Phone: 704-645-5353 Fax: 704-645-5404 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: Physical Chemical treatment process including pH adjustment, chemical addition, and sludge settling. Sludge is dewatered by means of a plate press and removed as hazardous waste to a hazardous waste landfill in Pa. SUMMARY AND COMMENTS: Audit Comments: HWA is currently under review and correction. The IUP has expired and should he reissued with an expiration date of 6/30/08. The 1UP based on the new HWA should be issued effective 7/1/2008. The IWS was submitted to the Division on 6/8/2005. The POTW has not received correspondence from the Division approving the IWS or requesting more information. Requirements: See the Program Elements Review Section of this report. Recommendations: NOD: ❑ Yes ® No NOV: ❑ Yes ® No QNCR: ❑ Yes ® No POTW Rating: Satisfactory ® Marginal ❑ Unsatisfactory ❑ Audit COMPLETED BY: DATE: April 11, 2008 JohrUley, Mooresville R al Office NC DWQ Pretreatment Audit Form Revised: July 25, 2007 Page 6 Michael F. Easley, GovemJib- orK William G. Ross Jr., Secret North Carolina Department of Environment and Natural Resources April 12, 2007 The Honorable James A. Brown, Mayor Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Subject: Pretreatment Annual Report Town of Cleveland NPDES Permit No. NCO049867 Rowan County, NC Dear Mayor Brown: Alan W. Klimek, P. E. Director Division of Water Quality Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR) for the reporting period of January through December 2006. Based on the review, it appears that the POTW completed the PAR in accordance with 15A NCAC 2H .0908(b) requirements and guidelines set forth in Comprehensive Guidance for North Carolina Pretreatment Proprams. The next PAR will be due March 1, 2008. If you have any questions concerning your PAR, please do not hesitate to contact me at (704) 663-1699 or by email at John.Lesley@ncmail.net. Sincerely, `John Lesley Mooresville Regional Office Contact Cc: Tom Ascenzo, PERCS Unit Central Files No;e hCarolina 'Nalul'all1f N. C. Division of Water Quality, Mooresville Regional Office, 610 E. Center Ave. Suite 301, Mooresville NC 28115 (704) 663-1699 Customer Service 1-877-623-6748 O�0F W A'r' pG Michael F. Easley, Govemor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources p Alan W. Klimek, P.E. Director Division of Water Quality November 15, 2006 The Honorable James A. Brown, Mayor Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Subject: Pretreatment Compliance Inspection Town of Cleveland NPDES Permit No. NC0049867 Rowan County, NC Dear Mayor Brown: Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection of the TowWs approved Industrial Pretreatment Program on November 8, 2006 by Mr. John Lesley of this Office. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Mr. Lesley or me at (704) 663-1699. ` Sin�cl ely, f Michael Parker Acting Regional Supervisor Surface Water Protection Enclosure cc: Central Files Tom Ascenzo, PERCS Unit Rowan County Health Department JL ��� N"os�enCarolina NCDENR �Vaturallr� Mooresville Regional Office Division of Water Quality Phone 704-663-1699 Customer Service Internet: ivNv%v.ncwatcroualitv.or:, 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax 704-663-6040 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper NORTH CAROLINA DIVISION OF WATER QUALITY PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT BACKGROUND INFORMATION lComolete Prior To PCI: Review Program Info Database Sheetfs OF WArFR L.JWIX 1. Control Authority (POTW) Name: Town of Cleveland 2. Control Authority Representative(s): Dena Myers and Tracy Moore Telephone: 704-878-4697 Fax: 704-878-2787 3. Title(s): Pretreatment Program Consultants - Statesville Analytical E-mail: denameyers@i-america.net 4. Last Inspection Date: 10 /14 /2005 Inspection Type: ® PCI ❑ Audit 5. Has Program Completed All Requirements from the Previous Inspection or Program Info Sheet(s)? ® Yes ❑ No 6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA PCS CODING Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector I N I I N I C 10 10 14 19 1 R 16 17 1 Ill 1 0R 106 1 LP-1 LEI ACC) Fac. Type LLJ (F (DTIA) (TYPI SP) POTW INTERVIEW 17 18. 19. Since the Last PCI, has the POTW had any POTW Permit Limits Violations? If Yes, What are the Parameters and How are these Problems Being Addressed? (See Comments Section) 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? N Yes " No TSS - 3/2006 not SIU related ME 0.210 Which Industries have been in SNC during either of the Last 2 Semi- SNC for Limits: NA Annual Periods? Have any Industries in SNC (During Either of the Last SNC for Reporting: NA 2 Semi -Annual Periods) Not Been Published for Public Notice? Not Published: NA (May refer to PAR if Excessive SIUs in SNC) 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 ❑ Yes ® No Ones? Filename: Cleveland PCI 0607 Page 1 Revised: 6/30/98 Pr7 ATMENT PROGRAM ELEMENTS REVIEW- Please review POTW files and complete the following: Program Element Date of Last Approval Date Next Due, If Applicable Headworks Analysis (HWA) 10/6/04 6/1/07 Industrial Waste Survey (IWS) 3/27/00 submitted on 6/8/05 Sewer Use Ordinance.(SUO) 12/20/04 6/1/07 Enforcement Response Plan (ERP) 12/28/94 Short Term Monitoring Plan (LTMP) 9/29/00 5/1/06 * see Requirements Section STMP FILE REVIEW: 22. Is the STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® Yes ❑ No 23. Should any Pollutants of Concern be Eliminated from or Added to the STMP? ❑ Yes ® No If yes, which ones? Eliminated: Added: 24. Are Correct Detection Levels being used for all STMP Monitoring? ® Yes ❑ No 25. Is the STMP Data Maintained in a Table or Equivalent? ® Yes ❑ No Is the Table Adequate? ® Yes ❑ No INDUSTRIAL USER PERMIT IUP FILE REVIEW 3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION 26. User Name 1. Freightliner 2. 3. 27. lUP Number 0001 28. Does File Contain Current Permit? ® Yes ❑ No ❑Yes ❑ No El Yes El No 29. Permit Expiration Date 8/31/2007 30. Categorical Standard Applied .E. 40 CFR, Etc. Or N/A 433.17 31. Does File Contain Permit Application Completed Within One Year Prior to Permit Issue Date? ® Yes ❑ No El Yes ❑ No ❑ Yes ❑ No 32. Does File Contain an Inspection Completed Within Last Calendar Year? Yes ❑ No 1 ❑ Yes ❑ No 1 ElYes No 33. a. Does the File Contain a Slug Control Plan? b. If No, is One Needed? See Inspection Form from POT a. ®Yes ❑No b. []Yes❑No a. ❑Yes ONO b. ❑Yes []No a. ❑Yes ❑No b. []Yes ❑No 34. For 40 CFR 413 and 433 TTO Certifiers, Does File Contain a Toxic Organic Management Plan (TOMP)? ❑Yes❑NoON/A conducts TFO anal ses ❑Yes❑No❑N/A ❑Yes❑No❑N/A 35. a. Does File Contain Original Permit Review Letter from the Division? b. All Issues Resolved? a. ®Yes ❑No baYes❑No❑N/A a. []Yes[]No b.❑Yes❑No❑N/A a. []YesNo b.❑Yes❑No❑N/A 36. During the Most Recent Semi -Annual Period, Did the POTW Complete its SamplingSamp4pg as Re uired by IUP? 0 Yes El No ❑Yes ❑ No ❑ Yes ' ❑ No 37. Does File Contain POTW Sampling Chain-Of-CustodyForms? ® Yes ❑ No ❑ Yes ❑ No Yes No 38. During the Most Recent Semi -Annual Period, Did the SIU Complete its Sampling as Required by IUP? NYes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 39. Does Sampling Indicate Flow or Production? OYes❑No❑N/A ❑YesDNo❑N/A ❑Yes❑No❑N/A 40. During the Most Recent Semi -Annual Period, Did the POTW Identify All Non -Compliance from Both POTW and SIU Sampling? El Yes Ej No ®NA ❑ Yes ❑ No ❑ NA ❑ Yes ❑ No ❑ NA 41. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self- Monitoring Violations? b. Did Industry Resam le Within 30 Days? . a.❑Yes❑No®N/A b. []Yes []No a.❑Yes❑No❑N/A b. 0Yes ❑No a.❑Yes❑No❑N/A b. ❑Yes ❑No 42. Was the SIU Promptly Notified of Any Violations (Per ERP)? [3Yes❑NoON/A ❑YesDNo❑N/A ❑Yes❑No❑N/A 43. During the Most Recent Semi -Annual Period, Was the SIU in SNC? ❑ Yes ® No 11 ❑ Yes ❑ No 11 ❑ Yes ❑ No 44. During the Most Recent Semi -Annual Period, Was Enforcement Taken as Specified in the POTWs ERP? ❑Yes❑NoON/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 45. Does the File Contain Penal Assessment Notices? ❑Yes❑No®N/A ❑YesDNo❑N/A ❑YespNo❑N/A 46. Does The File Contain Proof Of Penalty Collection? ❑Yes❑No®N/A OYes❑No❑N/A ❑Yes❑No❑N/A 47. a. Does the File Contain Any Current Enforcement Orders? b. Is SIU in Compliance with Order9 a.❑Yes❑No®N/A b.❑Yes❑NowN/A a.❑Yes❑No❑N/A b.[3Yes❑No❑NIA a.❑Yes❑No❑N/A b.❑Yes❑No❑N/A 48. Did the POTW Representative Have Difficulty in Obtaining Any of This Requested Information For You?1 ❑ Yes ®No ❑Yes ❑ No 11 ❑ Yes No Filename: Cleveland PC] 0607 Page 2 Revised: 6/30/98 FILE REVIEW COMMENTS: -14 1. Freightliner personnel sets up the composite sampler and Pace Analytical staff picks up the sample for analyses. The sample start time is not being recorded on the chain of custody form (Pace Analytical staff is recording the stop time). Be advised that Freightliner staff must record the start time on the chain of custody form to document that a full 24-hour composite has been collected. Freightliner staff must also sign or initial the chain of custody form documenting who started the sample collection process. Failure to do so may be cause to invalidate the data. 2. Calibration of pH monitoring equipment that is used for reporting purposes must meet 40 CFR 136 criteria, including Quality Assurance - Quality Control documentation. Writing "meter calibrated" in the calibration log is not sufficient QA/QC documentation of calibration procedures. All pH sample collection times and analysis times must also be recorded and initialed by the person collecting the sample and the analyst performing the test to document that the 15-minute holding time is not exceeded. The POTW will provide guidance to Freightliner staff for recording calibration and sampling data (calibration log sheets and sample chain of custody forms for the pH samples).. .3. The HWA is due on 6/1/2007. The Freightliner IUP expires on 8/31/2007. The POTW may extend the IUP expiration date to 12/31/2007 in order to have sufficient time to prepare the IUP using data from the most recently approved HWA..Be advised that any changes to the IUP must be submitted to the PERCS Unit for approval and the changes included in the permit history. PCI SUMMARY AND COMMENTS: PCI Comments: 1. The Town's Pretreatment Program was well managed and organized. All documentation was provided by Statesville Analytical staff. Requirements: 1. The STMP due date is listed as 5/1/2006. The POTW has experienced no changes in the WWTP or SIU since the STMP was approved on 9/29/2000; therefore, a new STMP was not submitted. Please revise the mercury effluent MDL to method 1631 and submit the change to the PERCS Unit so the facility's STMP file can be kept current. 2. The Town's Pretreatment Consultants reoresented the POTW during this inspection. All future inspections will require that the Town's designated Pretreatment Coordinator be present. 3. Reauired due dates are listed in the Pretreatment Program Elements Review Section of this report. Recommendations: NOD: ❑ Yes ® No NOV: QNCR: POTW Rating: ❑ Yes ® No ❑ Yes ® No Satisfactory ® Mar 'nal ❑ Unsatisfactory ❑ PCI COMPLETED BY: DATE: November 14, 2006 J Lesley, Mooresvill egional Office Filename: Cleveland PCI 0607 Page 3 Revised: 6/30/98 WATER QG Michael F. Easley, G vemor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources September 12, 2006 The Honorable James A. Brown, Mayor Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Subject:. PAR Review Town of Cleveland NPDES Permit No.NC0049867 Rowan,County, NC Dear Mr. Brown: Alan W. Klimek, P.E. Director Division of Water Quality . Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR) for the reporting period of January through December 2005. Based on the review that included the additional information concerning the adjudication of the SNC status for Freightliner, it appears that the POTW completed the PAR in accordance with guidelines set forth by the Division for modified pretreatment programs. If you have any questions concerning your PAR, please do not hesitate to contact John Lesley of this Office at (704) 663-1699. Sincerely, L D. Rex Gleason, . Surface Water Protection Regional Supervisor Cc: Tom Ascenzo, PERCS Unit Central Files Rim ®Atur o'ina WDENR Mooresville Regional Office Division of Water Quality Phone 704-663-1699 Customer Service Internet: www.ncwaterquality org 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax 704-663-6040 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper �F W ATF9 Michael F. Easley, Govem� (rLL-- AA QG William G. Ross Jr., Secretary C.0 f North Carolina Department of Environment and Natural Resources 5 Alan W. Klimek, P.E. Director Division of Water Quality April 18, 2006 The Honorable James A. Brown, Mayor Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Subject: PAR Review Town of Cleveland NPDES Permit No.N_C0049867 Rowan County, NC Dear Mr. Brown: Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR) for the reporting period of January through December 2005. Until the Town Board rules on Freightliner's appeal of the Significant Noncompliance for the period January — June 2005, a complete review of the PAR cannot be completed. Please submit a completed Pretreatment Program Summary page, and the necessary public notice (should the Town Board uphold the SNC status of Freightliner) to John Lesley of this Office and Jon Risgaard of the PERCS Unit as soon the appeal process has been completed. If you have any questions concerning your PAR, please do not hesitate to contact Mr. Lesley of this Office at (704) 663-1699. Cc: Jon Risgaard, PERCS Unit Central Files JL 7107 PICDENR Sincerely, D. Rex Gleason, P.E. Surface Water Protection Regional Supervisor Nne orthCarolina Natu ley Mooresville Regional Office Division of Water Quality Phone 704-663-1699 Customer Service Internet: www ncwaterqualitv.ore 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax 704-663-6040 1-877-623-6748 An Equal OpportunitylAffirmative Action Employer— 50% Recycled110% Post Consumer Paper Michael F. Easley, Cldvemor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek. P. E. Director Division of Water Quality October 19., 2005 CERTIFIED .MAII, - RETURN RECEIPT REQUESTED 7003 2260 00013492 7112 'The Honorable James A. Brown, Mayor Town of Cleveland Post Office Box 429 Cleveland,North.Carolina :27013 :Subject: Notice of Violation NOV 2005-PC-0232 -:Failure to implement Pretreatment Program NCGS 143-215.3(14) Town ofCleveland NPDES Permit No. -NC0049867 Rowan County, NC Dear Mayor Brown: Enclosed pis ,a,copy:.of :the Pretreatment °Compliance Inspection (PCl)'Reportfor the inspection of -the Town's;approvedIndustrial Pretreatment: Program conducted .on=October 14, 2005 by Mr. John:Lesley.ofthis --Office. This Report is -.being issued =as .a Notice of Violation.( NOV) because of violations of the subjectpermit, North --Carolina General:Statutes (G.-S.) 143=215.1, G.S.143-215.3(6)(14), and NC Administrative .Code 15A NCAC .2H . 0900 for failure to :properly. implement.the Pretreatment Program (see the PCI Report Summary and Comments `Section for details). Pursuant to G E. 143- 215.6A, a civil penalty of -mot more than twenty-five thousand dollars ($25.,000.00) may -be assessed:against:arly.person-who violates or fails :to -act in .accordance-witli the terns, :conditions, =or Tequirements�ofanypermit.-issued;pursuantto�G:S.143-215.1: ^Shouldtlusl0fficemake.an enforcement Tecommendation_relative to the violations; you willbe advised in writing. Please note the following requirements: 1. ANotice,ofViolationmust be:issuedtoFreightliner.addressing Freightliner's failure :to report :noncompliance within 24 hours as required 'by the ndustry's Industrial User Permit. The Notice of Violation must be sent to Freightliner and a. copy forwarded to Mr. Lesley of this Office by no later than November 20, 2005. I&tCajr--rrr!r� J N. C. Division of Water Quality, Mooresville Regional Office, 610 E. Center Ave. Suite 301, Mooresville NC 28115 (704) 663d699 Customer Service 1-877-623-6748 2. A Notice of Violation must be "issued to Freightliner addressing Freightliner's failure to submit a report of sample.: analysis within 30 -days :following noncompliance -for. zinc:as required by the;industrf s Industrial User :Permit. The Notice:of Violation :must be. sent to Freightliner -and a copy forwarded .to Mr."Lesley of .this -Office :by :no later than November 20, . 2005. Thexeport.should be self --explanatory; however, should you have.any, questions concerning this report, please do not:hesitate to contact'Mr. Lesley or me .at -(704) 663-1699. , -Sincerely, D. Rex _Gleason, P.E. 'Surface Water Protection Regional Supervisor Enclosure cc: Central Files Jon Risgaard, Pretreatment -Group Rowan County Health Department JL NORTH CAROLINA DIVISION OF WATER QUALITY wArFRo PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT E ACDENR o BACKGROUND INFORMATION (Complete Prior To PCI; Review Program Info Database Sheet(s)l 1. Control Authority (POTW)Name: Town of Cleveland 2. 'Control Authority Representative(s): Ms. Dena Myers, Ms. Tracy Moore Telephone: 704472-4697 Fax: 704-878-2787 3. Title(s):.Pretreatment-Program Consultants- Statesville Analytical E-mail: denamyers@i-america.net 4. Last Inspection Date: 05 /11 /05 Inspection -Type: O PCI `❑ Audit 5. Has Program`Comlileted All Requirements from -the Previous Inspection or Program Info Sheet(s)? .® Yes ❑ No 6.- Is POTW:under:an Order. That Includes Pretreatment -Conditions? .❑ Yes ®.No Order Type -and Number: AreAfilestone Dates Being Met? ❑ Yes '❑ No .® NA PCS CODING Trans. -Code Main Program Permit Number MMMD/YY Inspec.Type Inspector I N I I N I C 10 1-0 14 19 J R 1' 6 17 1 .1 10 1 14 1 <ns I LEJ LSJ Fac. Type L LI (FACC) -(DT1A) (TYPI (INSP) 7. Current Number Of Si "ficant Industrial Users (SIUs)? 1 SILTS 8. Current Number Of CategoricalIndustrialUsers CIUs)? 1 CIUS �9. Number of SIUs Not Ins ectedB POTW in the Last •Calendar Year? -0 '10.Number of'SIUsNot Sampled B POTW inthe Last Calendar•Year? 0 14. Enter the Hi er.Number of 9.or-10 0 NOIN 12.Number -of`SIUs`WithNo'1UP, or With znExpired IUP 0 NOCM 13. Number of.SIUs:mSNC for.`Either Reporting or -Limits Violations During Either ofthe Last 'Semi -Annual Periods•(:TotalNumber of SIUs in 'SNC) 1 PSNC 14. Number of SlUs'm'SNC Forge ortin DuringEither of the Last 2 Semi -Annual Periods -0 MSNC 15. Number of SIUs In SNC For Limits Violations During Either of.the Last 2 Semi -Annual Periods 1 SNPS 1-6.Number ofSIUs In:SNCforBothR-eporting:andLimitsViolations During Either of the Last 2 Semi-annual Periods 0 POTW INTERVIEW 17.. Since the Last PC-I,--has-the-I,--has-thePOT-W -had any POTW Termit Limits Violations? ® Yes ❑ No If yes, Whatarethe Parameters and How:are.theseProblems Being Addressed. Ammonia 4/05 (See Comments `Section) ' Failed to sample'TP:and TN in 5105 18. 'Since theLast PCI, has the POTW.had any'Problems Related to an Industrial ❑ Yes ® No Discharge.(Interference, Pass -Through, Blockage, Citizens' -Complaints, Increased Sludge Production, Etc.)? If Yes, How -are these Problems Being Addressed? 19. Which Industries'havebeen in SNC during either of the Last 2 Semi- -SNC for Limits: Freightliner - Annual Periods? .Have any Industries in "SNC (During Either of the Last SNC for Reporting: NA 2 Semi -Annual Periods).Not Been Published for Public Notice? Not Published: NA see 21 below .(May .refer to PAR if Excessive SIUs in SNC) 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 ® Yes El No -Ones? See Comments Section Filename: Cleveland PCI 0506 NOV Page 1 Revised: 6/30/98 PRETREATMENT PROGRAM ELEMENTS REVIEW- Please review POTW files and comnlete the following*: Program Element Date of Last Approval Date Next Due, If Applicable Headworks Analysis (HWA) 3/30/04 6/1/07 Industrial Waste Survey (IWS) 3/27/00 Submitted 6/8/05 Sewer Use Ordinance (SUO) 12/20/04 12/1/06 Enforcement Response Plan (ERP) 12/28/94 12/1/06 Short Term Monitoring Plan (LTMP) 9/29/00 .5/1/06 STMP FILE REVIEW: 22. Is the STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® Yes .❑ No 23. Should any Pollutants of Concern be Eliminated from or Added to the STMP? ❑ Yes ® No If yes, which ones? Eliminated: Added: 24. Are Correct Detection Levels being used for all STMP Monitoring? ® Yes ❑ No 25. Is the STMP Data Maintained in a Table or Equivalent? ® Yes ❑ No Is the Table Adequate? ® Yes ❑ No INDUSTRIAL USER PERMIT (IUP) FILE REVIEW(3 ]UP FILE REVIEWS OR 1 FILE REVIEW AND 7 TT TNSPF.C`TTnNI 26. User Name 1. Freightliner 2. 3. 27. ILTP Number 0001 28. Does File Contain Current Permit? I ® Yes ❑ No 11 ❑ Yes ❑ NoI ❑ Yes ❑ .No 29. Permit Expiration Date 8/31/07 30. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 1 433.17 31. Does File Contain Permit Application Completed Within One Year Prior to Permit Issue Date? ® Yes ❑ No ❑Yes ❑ No ❑Yes ❑ No 22. Does File Contain an Inspection Completed Within Last Calendar Year? 33. a. Does the File Contain a Slug Control Plan? b. If No, is One Needed? (See Inspection Form from POT 1 ® Yes ❑ No ❑ Yes ❑ NoI ❑ Yes ❑ No a. ®Yes ❑No b. ❑Yes ❑No a. Yes []No b. ❑Yes ❑No 11 a. ❑Yes ❑No b. []Yes ❑No 34. For 40 CFR 413 :and 433 TTO Certifiers, Does File Contain a Toxic Organic Management Plan (TOMP)? ❑YespNo®N/A 11 ❑Yes❑No❑N/A_11 ❑Yes❑No❑N/A 35. a. Does File Contain Original Permit Review Letter from the Division? b. All Issues Resolved? a. ®Yes ❑No I baYes❑No❑N/A a. ❑Yes ❑No 'b.❑Yes❑No❑N/A a. ❑Yes ❑No b.❑Yes❑No❑N/A 36. During the Most Recent Semi -Annual Period, Did the POTW Complete its Sampling as Required b IUP? ® Yes ❑ No ❑ No iF� El Yes ElNq 11 37. Does File Contain POTW Sampling Chain -Of -Custody Forms? 38. During the Most Recent Semi -Annual Period, Did the SILT Complete its Sampling as Required b ]UP? 1 ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No ®Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 39. Does Sampling Indicate Flow or Production? 40. During the Most Recent Semi -Annual Period, Did the POTW Identify All Non -Compliance from Both POTW and SILT Sampling? OYes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A ® Yes ❑ No ❑ NA ❑ Yes ❑ No NA I El NA Yes ElNo ❑ NA 41. a. Was the POTW Notified'by SIU (Within 24 Hours) of All Self- Monitoring Violations? b. Did Industry Resam le Within 30 Days? a.❑Yes®No❑N/A b. ®Yes ❑No a.❑Yes❑No❑N/A b. ❑Yes ❑No a.❑Yes❑No❑N/A b. ❑Yes []No 42. Was the SIU Promptly Notified of Any Violations (Per ERP)? ❑Yes®No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 43. During the Most Recent Semi -Annual Period, Was the SIU in SNC? ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No 44. During the Most Recent Semi -Annual Period, Was Enforcement Taken as Specified in the POTWs ERP? ❑Yes®No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 45. Does the File Contain Penalty Assessment Notices? 46. Does The File Contain Proof Of Penalty Collection? 47. a. Does the File Contain Any Current Enforcement Orders? b. Is SILT in Compliance with Order? ®Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A ®Yes❑No❑N/A ❑Yes❑No❑N/A 11 ❑Yes❑No❑N/A 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 48. Did the POTW Representative Have Difficulty in Obtaining Any of This Requested Information For You? ❑ Yes ® No ❑ Yes ❑ No ❑Yes ❑ No Filename: Cleveland PCI 0506 NOV Page 2 Revised: 6/30/98 FILE REVIEW COMMENTS: Question 2 . The public official responsiblefor Pretreatment Program issues is Mr. Pat Phiefer, 704-798-2633, Sewer Commissioner. Question 21. Freightliner was placed in SNC for chronic and technical review criteria violations of the zinc limit in the permit that = = became effective on May 1, 2005. The-SIiJ has requested adjudication of the SNC status based on the limited number of samples -that were taken under -the newly issued permit.(the previous permit had a "monitoring only" requirement for zinc: A hearing has .been set for -October 25, 2005. PCI SUMMARY ANDCOMMENTS: PCI Comments: Ouestion 29. A modifiedyermit was issued on May 1, 2005. Question 33. The most recent -slug and spill•control plan was dated 6/712000. An updated plan should`be requested-fromahe SIU. . Question-34. The SIU-performs the TTO anavlses; therefore, _a TOW is not needed. Question 41. 'The SIU failed to notify the POTW ofviolations-of.the permit within 24 hours as reguired.by the]UP. The'IUP also requires that the SlUtake.a "'repeat sample.and submit test results within.30:days". TheSIU's regular sampling for the -next month was taken within 30 -days of:thenoncompliance;however, Freightliner did not submit the .required -report within 30 days. Question 42. The:POTW did not send the SIU a Notice of Violationfor failing to.report thewiolation within 24 hours or for failing to submit .the -test data-reguired of the repeat sample within 30 days. sOuestion 44. The POTW's Enforcement Response Plan requires that a Notice -of Violation be issued for -reporting violations. .Requirements: 1. Please note the due dates for pretreatment program elements in the Pretreatment .Program Elements Review Section of this 'report. 2. ANotice of Violation must'be sent to:Freightliner for failure to report noncompliance within 24'hours of first knowledge. 3. The resamplingseauirement,in the -the does not state that. -the repeat samples must be in additon to regular monthiv•sam fling, butreauiresthe submittal of the repeat -sample results within-30 days from the date of first knowledge of the violation. Freightliner . - did not submit a :report within 30 days as required -by the permit Ithe sampling event was,near the vend of the 30 day window). Because the SIU felt thereeular monthly sampline would suffice for -the repeat sample requirement, an additional sample was not ,taken. ANotice of Violation wasnot-submitted forthe"failureto submit the report within the 30 days required by the permit. This Office will reguirethata Notice of Violation:be-submitted to the-SlU-for'failing to submit.a report of the repeat sample within the 30 day requirement as specified in the IUP. 4. The POTW must submit;the.above required Notices of Violation and copy John Lesley of this Office by•no later than November 20, 2005. Recommendations: This Office -recommends that the POTW rediewthe language of therepeat sampling requirement in the IUP. lUP language should specify if the repeat sample is to be in addition to the monthly sampling requirement. NOD: ❑ Yes ❑ No NOV.: ® Yes ❑ No ,-QNCR: ❑ Yes .❑ .No POTW Rating: Satisfactory ❑ Marginal 22 Unsatisfactory ❑ PCI COMPLETED BY: DATE: October 17, 2005 J esley, Mooresville Re oral Office Filename: -Cleveland PCI 0506 NOV Page 3 Revised: 6130/98 Michael F. Easley, Govern. ' William G. Ross Jr., Secreta North Carolina Department of Environment and Natural Resourc Alan W. Klimek, P. E. Director Division of Water Quality May.12, 2005 The Honorable James A. Brown, Mayor Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Subject: Pretreatment Compliance Inspection Town of Cleveland WWTP NPDES Pen -nit No. NCO049867 Rowan County, NC Dear Mayor Brown: Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection of the Town of Cleveland approved hidustrial Pretreatment Program on May 11, 2005 by Mr. John Lesley of this Office. Please see the Program Elements Review Section of this report for a summary of upcoming submittals. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Mr. Lesley or me at (704) 663-1699. Sincerely, -� D. Rex Gleason, P.E. / Surface Water Protection Regional Supervisor Enclosure cc: Central Files Dana Folley, Pretreatment Group Rowan County Health Department Dena Myers, Statesville Analytical 11-0 One NorthCuolina ;%vQtwallly N. C. Division of Water Quality, Mooresville Regional Office, 610 E. Center Ave. Suite 301, Mooresville NC 28115 (704) 663-1699 Customer Service 1-877-623-6748 NORTH CAROLINA DIVISION OF WATER QUALITY NC®ENR PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT M.,,,� C__ t-rw R w.nq,.ligEwt •.v', !iat!.wi, ii¢SU'_wGCs BACKGROUND INFORMATION (Complete Prior To PCI; Review Program Info Database Sheet(s)l 1. Control Authority (POTW) Name: Town of Cleveland 2. Control Authority Representativc(s): Ms. Dena Myers, Ms. Tracy Moore Telephone: 704-872-4697 Fax: 704-878-2787 3. Title(s): Pretreatment Consultants -Statesville Analytical E-mail: denamyers@i-america.net 4. Last Inspection Date: 06 /02 /2004 Inspection Type: ® PCI ❑ Audit 5. Has Program Completed All Requirements from the Previous Inspection or Program Info Sheet(s)? ❑ Yes ® No* seecomments 6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA PCS CODING Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector I N I C 1 0 101419 18 16 17 05111 1051 Fac. Type LLJ (FACC) (DTIA) (TYPI) (INSP) 7. Current Number Of Si-nificant Industrial Users (SIUs)? 1 SIUS 8. Current Number Of Categorical Industrial Users (CIUs)? 1 CIUS 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. Enter the Higher Number of 9 or 10 0 NOIN 12. Number of SIUS With No IUP, or With an Expired IUP 0 NOCM 13. Number of SIUS in SNC for Either Reporting or Limits Violations During Either of the Last 2 Semi -Annual Periods (Total Number of SIUS in SNC) 1 PSNC 14. Number of SIUS in SNC For Reporting During Either of the Last 2 Semi -Annual Periods 0 MSNC 15. Number of SIUS In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods 1 SNPS 16. Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2 Semi-annual Periods 0 POTW INTERVIEW 17. Since the Last PCI, has the POTW had any POTW Permit Limits Violations? ® Yes ❑ No If Yes, What are the Parameters and How are these Problems Being Addressed? 12/04 Fecal Coliform (See Comments Section) 7/04 Dissolved Oxygen 18. Since the Last PCI, has the PO FW had any Problems Related to an Industrial ® Yes ❑ No Discharge (Interference, Pass -Through, Blockage, Citizens' Complaints, Increased WWTP Impact - foaming due to Sludge Production, Etc.)? surfactants from SIU If Yes, How are these Problems Being Addressed? 19. Which Industries have been in SNC during either of the Last 2 Semi- SNC for Limits: Freightliner Annual Periods? Have any Industries in SNC (During Either of the Last SNC for Reporting: None 2 Semi -Annual Periods) Not Been Published for Public Notice? Not Published: None (May refer to PAR if Excessive SIUs in SNC) 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 �❑ Yes ® No Ones? Filename: Cleveland PCI 0405 Page 1 Revised: 6/30/98 NPRETREATMENT PROGRANI ELE;NIENTS REVIEW- Please review POTW files and complete the following: ' Program Element Date of Last Approval Date Next Due, If Applicable Headworks Analysis (FIWA) 3/30/04 6/1/07 Industrial Waste Survey (INVS) 3/27/00 6/30/05* see comments Sewer Use Ordinance (SUO) 12/20/94 12/1/06* see comments Enforcement Response Plan (ERP) 12/28/94 Long Term Monitoring Plan (LTiAIP) 9/29/00 5/1/06 LTMP FILE REVIEW: 22. Is the LTMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® Yes ❑ No 23. Should any Pollutants of Concern be Eliminated firom or Added to the LIMP? [:]Yes ® No If yes, which ones'? Eliminated: Added: 24. Are Correct Detection Lev e!s being used for all LTNIP Monitoring? ® Yes ❑ No 25. Is the LTMP Data ivlaintaincd in a Table or Equivalent? ® Yes ❑ No Is the Table Adequate? ® Yes ❑ No INDUSTRIAL USER PERMIT (IUP) FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION) 26. User Name 1. Freightliner 2. 3. 27. IUP Number 0001 28. Does File Contain Current Permit? Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No 29. Permit Expiration Date 8/31/07 30. Categorical Standard Applied (I.L. 40 CFR, Etc.) Or N/A 433.17 31. Does File Contain Permit Applica!on ,"btnpleted Within One Year Prior to Permit Issue Date'? ® Yes ❑ No ❑ Yes ❑ No ❑Yes [:1 No 22. Does File Contain an Inspection Completed Within Last Calendar Year? ® Yes ❑ No ❑ Yes ❑ Rol ❑ Yes ❑ No 33. a. Does the File Contain a Slu; C0Iltr01 Plan? b. If No, is One Needed'? (Sce Inspection Form from POTW) a. NYes ❑No b. []Yes ❑No a. ❑Yes ❑No b. ❑Yes ❑No a. ❑Yes ❑No b. ❑Yes [:]No] 34. For 40 CFR 413 and 433 TTO Certifiers, Does File Contain a Toxic Organic Management Plan (TOPOP)? ❑Yes❑Noll ❑Yes❑No❑N/A ❑Yes❑No❑N/A 35. a. Does File Contain Ori-inal Pcrinit Review Letter from the Division? b. All Issues Resolved'? a. NYes ❑No b.®Yes❑No❑N/A a. ❑Yes ❑No b.❑Yes❑No❑N/A a. ❑Yes ❑No b.❑Yes❑No❑N/A 36. During the Most Recent Semi -Annual Period, Did the POTW Complete its Sampling as Required by IUI'Y ® Yes ❑ No IFO-Y� No ❑ Yes ❑ !11 1 37. Does File Contain POTb\' Samplims .'pain -Of -Custody Forms? ® Yes ❑ No ❑ Yes ❑ N`711 ❑ Yes ❑ No 38. During the Most Recent Scmi-AIIIiUaI Period, Did the SIU Complete its Sampling as Required by IUP? ®Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 39. Does Sampling Indicate Flow or Production? EYes❑No❑N/A J1 ❑Yes❑No❑N/A ❑Yes❑No❑N/A 40. During the Most Recent Semi -Annual Period, Did the POTW Identify All Non -Compliance from Both POTW and SIU Sampling? ® Yes ❑ No ❑ NA ❑ Yes ❑ No ❑ NA ❑ Yes [INo ❑ NA 41. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self- Monitoring Violations'? b. Did Industry Resample Within 330 Days? a.®Yes❑No❑N/A b. NYes ❑No a.❑Yes❑No❑N/A b. ❑Yes ❑No a.❑Yes❑No❑N/A b. ❑Yes ❑No 42. Was the SIU Promptly Notified of ,\nv Violations (PerERP)? ®Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 43. During the Most Recent Scmi-i\nwal Period, Was the SIU in SNC? ®Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No 44. During the Most Recent nnual Period, Was Enforcement Taken as Specified in the POT\\,s ERP:' ®Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 45. Does the File Contain Penalty Assessment Notices? NYes❑No❑N/A 11 ❑Yes❑No❑N/A ❑Yes❑No❑N/A 46. Does The File Contain Proof Ol' Penalty Collection? NYes❑No❑N/A 11 ❑Yes❑No❑N/A ❑Yes❑No❑N/A 47. 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 48. Did the POTW Representative I lave Difficulty in Obtaining Any of This Requested Information For You'? ❑ Yes ®No ❑Yes ❑ No ❑Yes ❑ No Filename: Cleveland PCt 040-� Page 2 Revised: 6/30/99 FILE REVIEW COMIIMENTS: "41 Freightliner was placed in SNC for discharging surfactants that caused a significant impact on the WWTP and for violation of the SUO. 2. The approval letter for the iUP from the Division consisted of an e-mail correspondence. 3. Freightliner conducts annual 'i"1'O :uialyses; therefore, a TOMP is not required. PCI SUMMARY AND CO:I'IA l i? `J i PCI Comments: The Town of" Cie viand's Pretreatment Program has shown significant improvement since the previous inspection Requirements: 1. A due date of 11/1/2004 was deli=-nared for submission of an Industrial Waste Survev (IWS). Because the Town conducts an on- going IWS, a formal IWS was not sent to the PERCS Unit. Be advised that an Industrial Waste Survey summary must be submitted to the PERCS Unit by no later than .,' une 30, 2005. The IWS summary must include two sources of survey information such as water billinlz records, sewer comiection nc�rniits, business license records etc. (See Chapter 3 of the Comprehensive Guidance Manual for instructions on what to send in tlic suniniary . 2. The Sewer Use Ordinance un(it e isee Sewer Use Ordinance Update correspondence dated December 10 2004) is due December 1, 2006. Recommendations: 1. Continue to implement changes ntude since the previous inspection regarding records filing and data management. 2. The Town's designated Pretreatment Program Coordinator should be present for all future Pretreatment Compliance Inspections. NOD: NOV: QNCR: POTW RatinE: [:]Yes* ® No ❑ Yes ® No ❑ Yes Nu Satisfactory ® Marginal ❑ Unsatisfactory ❑ /7 / 1, PCI COMPLETED BY: DATE: May 12, 2005 Jolr'iL ooresville Regioi al Office Filename: Cleveland PCI 0405 Page 3 Revised: 6/30/98 4d,--- Michael F. Easley, Gove o William G. Ross Jr., Secre ry North Carolina Department of Environment and Natural Resources May 2, 2005 The Honorable James A. Brown, Mayor Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Subject: PAR Review Town of Cleveland NPDES Permit No.NC0049867 Rowan County, NC Dear Mr. Brown: Alan W. Klimek, P. E. Director Division of Water Quality Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR) for the reporting period of January through December 2004. Based on the review that included the revisions made to the PAR by the Town's consultant, it appears that the POTW completed the PAR in accordance with guidelines set forth by the Division for modified pretreatment programs If you have any questions concerning your PAR, please do not hesitate to contact John Lesley of this Office at (704) 663-1699. Sincerely, ,:�� f r, Y D. Rex Gleason, P.E. Water Quality Regional Supervisor Cc: Dana Folley, Pretreatment Unit - Central Office Central Files JL N it liCarolina )Vat,11ally N. C. Division of Water Quality, Mooresville Regional Office, 610 E. Center Ave. Suite 301, Mooresville NC 28115 (704) 663-1699 Customer Service 1-877-623-6748 OG � 1r >_ 7 CERTIFIED MAIL RETURN RECEIPT REQUESTED The Honorable James A. Brown, Mayor Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Subject: Dear Mayor Brown: j C.L Michael F. Easley. Governor William G. Ross Jr.. S==Lry North Carolina Department of Environment and Natural Resourua Alan W. Klimek. P. E. Director Division of Water Quality Colecn H. Sullins. Deputy Director Division ofWatcr Qualiq June 23, 2004 Notice of Violation Failure to implement Pretreatment Program NCGS 143-215.3(14) Town of Cleveland NPDES Permit No. NCO049867 Rowan County, NC Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection of the Town's approved Industrial Pretreatment Program on June 2, 2004 by Mr. John Lesley of this Office and Ms. Dana Folley of the Division's Central Office. " This Report is being issued as a Notice of Violation (NOV) because of violations of the subject permit and North Carolina General Statute (G.S.) 143-215.1, G.S.143-215.3(a)(14), and 15A NCAC 2H .0900 for failure to properly implement the Pretreatment Program (see the PCI Summary and Comments Section for details). Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or f4s to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1. Should this Office make an enforcement recommendation relative to the violations, you will be advisedin writing. NorthC'-arolina IVaturallr� N. C. Division of Ware: Quality, dV KAF NCDEN� Mooresville Remonal Office, 919 North Main Street, Mooresville NC 28115 (704) 663-1699 Customer Service 1-877-623-6748 I Please note the following requirements: 1. The Town must issue an approved Industrial User Permit (IUP) with enforced monitoring frequencies by no later than August 1, 2004. 2. The Town must issue a Notice -of Violation to Freightliner for the industry's failure to monitor for chromium at outfall 002 as required by the current IUP by no later than August 1, 2004. 3. The Town must issue a Notice of Violation to Freightliner for the industry's failure to conduct additional mercury analyses as required by the current IUP by no later that July 20, 2004. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Mr. Lesley or me at (704) 663-1699. Enclosure cc: Central Files JL Sincerely, Nl D. Rex Gleason, P.E. Water Quality Regional Supervisor Dana Folley, Pretreatment Group Rowan County Health Department 44V -7 NORTH CAROLINA DIVISION OF WATER QUALITY NC®ENR PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Shect(s)l 1. Control Authority (POTW) Name: Town of Cleveland 2. Control Authority Representative(s): Dena Myers / Statesville Analytical Telephone: 704-872-4697 Fax: 704-878-2787 3. Title(s): Pretreatment Consultant E-mail: denamyers@I-america.net 4. Last Inspection Date: 04 /08 /2003 Inspection Type: ® PCI ❑ Audit 5. Has Program Completed All Requirements from the Previous Inspection or Program Info Sheet(s)? ® Yes ❑ No 6. is POTW under an Order That Includes Pretreatment Conditions? []Yes ® No Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA PCS CODING Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector I N I I N I C 1 0 1 0 1 4 1 9 I R 1 6 1 7 I 106 1 02 1 04 1 L-P- J LEI Fac. Type LLJ (FACC) (DTIA) (7'YPl) (INSP) 7. Current Number Of Significant Industrial Users (SIUs)? 1 SIUS 8. Current Number Of Categorical Industrial Users (CIUs)? 1 CIUS 9. Number of SIUs Not Inspected B POTW in the Last Calendar Year? 0 10. Number of SIUs Not Sampled B POTW in the Last Calendar Year? 0 11. Enter the Higher Number of 9 or 10 0 NOIN 12. Number of SIUs With No IUP, or With an Expired IUP 0 NOCM 13. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2 Semi -Annual Periods (Total Number of SIUs in SNC) 0 PSNC 14. Number of SIUs in SNC For Reporting DuringEither of the Last 2 Semi -Annual Periods 0 MSNC 15. Number of SIUs In SNC For Limits Violations DuringEither of the Last 2 Semi -Annual Periods 0 SNPS 16. Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2 Semi-annual Periods 0 POTW INTERVIEW 17. Since the Last PCI, has the POTW had any POTW Permit Limits Violations? ® Yes ❑ No If Yes, What are the Parameters and How are these Problems Being Addressed? See Comments Section (See Comments Section) 18. Since the Last PCI, has the POTW had any Problems Related to an Industrial ❑ Yes ® No Discharge (Interference, Pass -Through, Blockage, Citizens' Complaints, Increased Sludge Production, Etc.)? If Yes, How are these Problems Being Addressed? 19. Which Industries have been in SNC during either of the Last 2 Semi- SNC for Limits: NA Annual Periods? Have any Industries in SNC (During Either of the Last SNC for Reporting: NA 2 Semi -Annual Periods) Not Been Published for Public Notice? Not Published: NA (May refer to PAR if Excessive SIUs in SNC) 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 ❑ Yes ® No Ones? Filename: Cleveland PCI 03-04.dana Page I Revised: 6/30/98 PRETREATMENT PROGRAM ELEMENTS REVIE\)'- I'lease review PU I W tiles and complete the tollowtnl: Program Element Date of Last Approval Date Nest Duc. If Applicable Headworks Analysis (HNVA) 3/30/00 6/1/07 Industrial Waste Survey (IN't'S) 3/27/00 1 l/l/04 Sever Use Ordinance (SUO) 12/20/94 Enforcement Response Plan (ERP) 12/28/94 Long Term Monitoring Plan (LTMP) 9/29/00 5/l/06 LTMP FILE REVIEW: 22. Is the LTMP Monitoring Being Conducted at Appropriate Locations and Frequencies? Z Yes ❑ No 23. Should any Pollutants of Concern be Eliminated from or Added to the LTMP? ❑ Yes ® No If yes, which ones? Eliminated: Added: 24. Are Correct Detection Levels being used for all LTMP Monitoring? ® Yes ❑ No 25. Is the LTMP Data Maintained in a Table or Equivalent? ® Yes ❑ No Is the Table Adequate? E Yes ❑ No TNTITTCTRTAT. TTNER PERMTT MTPI MY REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION) 26. User Name 1. Freightliner Inc. IF 2. 3. 27. IUP Number 0001 28. Does File Contain Current Permit? ® Yes ❑ No 11 ❑ Yes ❑ No ❑ Yes ❑ No 29. Permit Expiration Date 8131/07 30. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 433.17 31. Does File Contain Permit Application Completed Within One Year Prior to Permit Issue Date? ® Yes ❑ No ❑ Yes ❑ No ❑ Yes ❑ No 22. Does File Contain an Inspection Completed Within Last Calendar Year? I ® Yes El No 11 [:]Yes ❑ No ❑Yes [:1 No 33. a. Does the File Contain a Slug Control Plan? See Comments b. If No, is One Needed? (See Inspection Form from POTW) a. ®Yes ❑No 1b. ❑Yes ❑No a. ❑Yes ONO b. ❑Yes ❑No a. ❑Yes ❑No b. ❑Yes ❑No 34. For 40 CFR 413 and 433 TTO Certifiers, Does File Contain a Toxic Organic Management Plan (TOMP)? See Comments ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑1'es❑No❑N/A 35. a. Does File Contain Original Permit Review Letter from the Division? b. All Issues Resolved? a. ®Yes ❑No I b.❑Yes®No❑N/A a. ❑Yes ❑No b.❑Yes❑No❑N/A a. ❑Yes ❑No b.❑Yes❑No❑N/A 36. During the Most Recent Semi -Annual Period, Did the POTW Complete its Sampling as Required by IUP? See Comments ❑ Yes ® No IF" ❑ No ❑ Yes ElNo 11 37. Does File Contain POTW Sampling Chain -Of -Custody Forms? ® Yes ❑ No ❑ Yes ❑ No 11 [:]Yes ❑ No 38. During the Most Recent Semi -Annual Period, Did the SIU Complete its Sampling as Required by IUP? See Comments ❑Yes®No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 39. Does Sampling Indicate Flow or Production? ®Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 40. During the Most Recent Semi -Annual Period, Did the POTW Identify All Non-Com liance from Both POTW and SIU Sampling? ® Yes El No ❑ NA __j❑ El Yes ❑ No NA ❑ Yes ❑ No ❑ NA 41. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self- Monitoring Violations? b. Did Industry Resam le Within 30 Days? a.❑Yes❑No®N/A b. ❑Yes ❑No a.❑Yes❑No❑N/A b. ❑Yes ❑No a.❑Yes❑No❑N/A b. ❑Yes ❑No 42. Was the SILT Promptly Notified of Any Violations (Per ERP)? See Comments ❑Yes®No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 11 43. During the Most Recent Semi -Annual Period, Was the SIU in SNC? ❑ Yes ® No ❑ Yes ❑ No ❑ Yes ❑ No 44. During the Most Recent Semi -Annual Period, Was Enforcement Taken as S ecified in the POTWs ERP? See Comments ❑Yes®No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 45. Does the File Contain Penalty Assessment Notices? ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 46. Does The File Contain Proof Of Penalty Collection? I ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A 47. 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 I a.❑Yes❑No❑N/A b.❑Yes❑No❑N/A a.❑Yes❑No❑N/A j[b.oYes0No[3N/A 48. Did the POTW Representative Have Difficulty in Obtaining Any of This Requested Information For You? ® Yes ❑ !][M_Yes_ ❑ No ❑ Yes ❑ No Filename: Cleveland PCI 03-04.dana Page 2 Revised: 6/30/98 F MISTRY INSPECTION PCS CODING: Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector LN lNIC10 10 14 19 IR 16 6 I2 14 I LW LEI (DTIA) (TYPI) t1NSP) 1. Industry Inspected: Freightliner 2. Industry Address: 11550 Statesville Blvd. Cleveland, NC 27013 3. Type of Industry/Product: Heavy Trucks 4. Industry Contact: Mr. John Casisa, REM Title: Environmental Engineering Phone: 704-645-5146 Fax: 704-645-5400 5. Does the POTW Use the Division Model Inspection Form or Equivalent? ❑ Yes ❑ No NA for this inspection 6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly? NA for this inspection Industrial Inspection Comments: Fac. I ype L: 1 (FACC) The Industry was inspected by DWQ staff to verify categorical processes, treatment units, and layout of collection system. FILE REVIEW COMMENTS: Question 33: A letter indicating that a new plan has been developed, but the plan itself could not be found. The POTW must obtain a current copy of the plan (mark out date copies void). The current plan must be reviewed and any required revisions made prior to December 31, 2004. Question 34: The SIU conducts the TTO analyses - a TOMP is not needed. Question 36: POTW sample analysis results for the Janurary - June 2003 period could not be located. The POTW did not record flow values in the July -December 2003 period and the correct MDL was not used for copper sampling. Temperature and pH documentation is not adequate, it was recorded in the space reserved for the lab, and the name of the collector/analyst is not recorded. Question 38: The SIU did not conduct chromium analyses for pipe 002 as required by the IUP. The POTW indicated that there were errors in the permit (originally issued August 31, 2002) and made some modifications to the IUP but did not correct the chromium frequency "error". The IUP was reissued February 2003 and still did not correct the weekly monitoring frequency for chromium "error" (other modifications had been made to the IUP). The SIU conducted chromium once per month instead of weekly. The POTW did not make the SIU aware of the monitoring violation, and continued to consider the monitoring frequency of weekly for chromium as an IUP error, but failed to take necessary actions to correct it. The SILT accepted the permit and did not object in writing to the weekly chromium monitoring frequency. Mercury samples were not analyzed in April 2004 due to a login error at the SIU's commercial laboratory. The IUP states that in the case of a lab error, an additional sample must be conducted in the following month (by May 20, 2004). The additional mercury sample was not collected and analyzed in May 2004. Question 42: See above comments Question 38. Question 44: The POTW did not take adequate action to correct the "error" of weekly monitoring for chromium in the IUP, nor did the POTW issue Notices of Violation for the failure to monitor chromium weekly as required by the IUP. Because of this lack of action by the POTW, the SIU did not seek written clarification of the weekly monitoring requirement for chromium (the POTW apparently had given verbal or other non -documented responses to the SIU that the monitoring frequency was in error). Question 48: The current POTW staff are relatively new and found the files in disarray when they started working with the program. The Sewer Use Ordinance approval letter, the Enforcement Response Plan (ERP) and the ERP approval letter were missing from the files (they were provided by DWQ staff during the inspection). PCI SUMMARY AND COMMENTS: 1. The POTW is not setting up samples independent of the SIU. The SIU staff collects all samples and splits with the POTW. The failure of the POTW to sample independentiv of the SIU is a violation of 15A NCAC 2H. 0908(d). Filename: Cleveland PCI 03-04.dana Pa.-e 3 Revised: 6/30/98 2. NPDES Compliance Summary — Question 17 wil 2003 Fecal Coliform 1 Weekh, Violation FA May 2003 BOD Weekly and INIonthh• Violations June 2003 BOD Weekly and I\Ionthh• Violations September 2003 Fecal Coliform Weekly(3) and Monthly Violations November 2003 TSS ' Weekl, and Monthl• Violations 'The TSS violations for November 2003 were determined to be due to sampling error. Requirements: General observation: The current pretreatment program staff has worked diligently to address a number of problems that were left by former staff. The DWO Central Office Pretreatment Unit is working closely with the POTW to correct problems and bring closure to several compliance issues. 1. The POTW must take samples independent of the SIU at least 1/6 months or more frequently as specified in the IUP. The POTVV may either use their own sampler (or hire a contract laboratory to collect the samples on their behalf) or use the SIU sampler. If the STU sampler is used the POTW must take responsibility for properly cleaning, programnunE. and take down of the equipment. All sampling procedures must be properly documented (sampler temperature, temperature of the sample when it is poured up into aliquots, sample collector's name. times the sampler started and stopped, etc.). 2. The POTW must issue an approved ][UP with sampling frequencies that it intends to enforce by no later than August 1, 2004 (if more time is needed please make the request in writing to the Division's Central Office ). 3. The POTW must issue a Notice of Violation to the SIU for failure to conduct chromium monitoring at outfall_002 as required by the IUP by no later than August 1. 2004. No civil penalties or significant non-compliance status need be included in the Notice due the inaction of the POTW to address this issue with the proper permit corrections or communication to the SIU (see Ouestion 44 comments above). 4. A Notice of Violation must be issued to the SIU for failing to collect the additional Mercury sample required by the IUP no later than August 20.2004 in accordance with the POTW's Enforcement Response Plan. Recommendations: 1. Copies of documents that are drafts should be clearly marked "DRAFT" in the file. Outdated copies of program elements should be clearly marked "VOID" in the file. Current program elements should be kept in files with "like items" (ie, IUP, STMP. SUO) and clearly labeled as the current issue of the document. Keep DWO approval letters with the item. or keep approval letters in other clearly marked files so they can be easilv located. NOD NOV: QNCR: POTW Rating: ❑ Yes ❑ No ® Yes ❑ No ❑ Yes ❑ No Satisfactory ❑ Marginal ® Unsatisfactory ❑ PCI COMPLETED BY: M.— 1`��DATE: June 23, 2004 Joh Lesley, Mooresville Regions Office Filename: Cleveland PCI03-04.dana Revised: 6/30/98 Pase 4 �oF \NA �i Michael F. Easley, Governor William G. Ross, Jr.,Secretary col North Carolina Department of Environment and Natural Resources O Y Alan W. Klimek, P.E., Director Division of Water Quality May 7, 2003 Mr. Fred Summers, Industrial Pretreatment Coordinator Town of Cleveland Post Office Box 429 Cleveland, North Carolina 27013 Subject: PAR Review Town of Cleveland NPDES Permit No.NC0049867 Rowan County, NC , Dear Mr. Summers: Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR) for the reporting period of January through December 2002. Based on the review, it appears that the POTW completed the PAR in accordance with guidelines set forth by the Division for, modified pretreatment programs. Please include a completed Pretreatment Performance Summary (PPS form) in future submissions of the PAR. If you have any questions concerning your PAR, please do not hesitate to contact John Lesley of this Office at (704) 663-1699. Sincerely, l D. Rex Gleason, P.E. ✓: Water Quality'Regional Supervisor Cc: Dana Folley, Pretreatment Unit - Central Office Central Files JL N-C-DENT Mooresville Regional Office, 919 North Main Street, Mooresville, NC 28115 PHONE (704) 663-1699 Customer Service FAX (704) 663-6040 1 800 623-7748