NC0049867_Inspection_20210701

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
CERTIFIED MAIL #: 7019 1120 0000 8362 0123
RETURN RECEIPT REQUESTED:
The Honorable Patrick Phifer, Mayor
Town of Cleveland
Post Office Box 429
Cleveland, North Carolina 27013
Dear Mayor Phifer:
NORTH CAROLINA
Environmental Quality
July 1, 2021
Subject: Notice of Violation
Pretreatment Compliance Inspection
Town of Cleveland
NPDES Permit No. NC0049867
Tracking #: NOV-2021-PC-0335
Rowan County
Enclosed is a copy of the Pretreatment Compliance Inspection (PCI) Report for the inspection of the Town of
Cleveland's Industrial Pretreatment Program on June 17, 2021, by Mr. Wes Bell of this Office.
This report is being issued as a Notice of Violation (NOV) due to the Town's failures to properly implement the
Pretreatment Program, violations of North Carolina General Statute (G.S.) 143-215.1, 15A North Carolina Administrative
Code (NCAC) 2H .0900 and NPDES Permit No. NC0049867. Specifically, the Town failed to initiate enforcement
according to the Division -approved Enforcement Response Plan (ERP) for the SIU's late submittal of a TTO Certification
and failures to monitor semi-annual metals (selenium, molybdenum and arsenic) during the second half of 2020. In addition,
the Town failed to collect a pH sample (per Industrial User Permit) during the second half of 2020. Please be advised that
G.S. 143-215.6A provides for a civil penalty assessment of not more than twenty-five thousand dollars ($25,000.00), or
twenty-five thousand dollars ($25,000.00) per day when the violation is of a continuing nature, against any person who
violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-
215.1.
In order to come back into compliance with the requirements of the Pretreatment Program, the Town must issue
appropriate enforcement actions to the SIU within fourteen (14) days of receipt of this inspection report. It is also requested
that a written response be submitted to this Office by July 23, 2021, addressing the Town's actions to prevent the recurrence
of the violations. The response should include a copy of the Town's enforcement actions. In responding, please address
your comments to the attention of Mr. Bell.
NORTH
Deparlmant of Environmental Ouallt
North
Carolina Department of Environmental Quality 1 Division of Water Resources
Mooresville Regional Office 1610 East Center Avenue, Suite 301 I Mooresville, North Carolina 28115
704.663.1699

The Honorable Patrick Phifer
Page Two
July 1, 2021
Should you have any questions concerning this Notice, please do not hesitate to contact Mr. Bell at (704) 235-
2192, or via email at [e-mail].
Enclosure:
Inspection Report
Sincerely,
DocuSigned by:
A w H P,xs.i
F161 FB69A2D84A3...
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W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
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NORTH CARIXINA
aeW Amen[ of Environmental Qual�
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1610 East Center Avenue, Suite 301 I Mooresville, North Carolina 28115
704.663.1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION:
1. Control Authority (POTW) Name: Town of Cleveland
2. Control Authority Representative(s):Barbara Sifford, Grant Marrs
3. Title(s): Pretreatment Consultant, WWTP Backup ORC
4. Last Inspection Date: 5/3/19 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
Main Program Permit Number
NC0049867
MM/DD/YY
06/17/21
7. Current Number Of Significant Industrial Users (SIUs)?
1
8. Number of SIUs With No IUP, or With an Expired IUP?
0
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year?
0
10. Number of SIUs Not Sampled By POTW in the Last Calendar Year?
0
11. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods?
0
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods?
0
13. Number of SIUs in SNC with Pretreatment Schedule?
0
14. Number of SIUs on Schedules?
0
15. Current Number Of Categorical Industrial Users (CIUs)?
1
16. Number of CIUs in SNC?
0
POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations?
If Yes, What are the Parameters and How are these Problems Being Addressed?
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
either of the Last 2 Semi -Annual Periods? Not Been Published for
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
SNC for
SNC for
Not Pul
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?
L YES ❑ NO
See Comments
❑ YES // NO
Limits: None
Reporting: None
)lished: N/A
N/A
❑ YES ONO
LTMP/STMP FILE REVIEW: Not Evaluated
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ❑ YES
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
❑ NO
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW:
Program Element
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
10/8/18
a Yes ❑ No
1/28/19
a Yes ❑ No
9/1/23
Industrial Waste Survey (IWS)
5/27/21
/1 Yes ❑ No
10/3/16
/1 Yes ❑ No
In Review
Sewer Use Ordinance (SUO)
1/18/13
a Yes ❑ No
1/23/13
r Yes ❑ No
Enforcement Response Plan (ERP)
2/12/20
a Yes ❑ No
2/14/20
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
6/15/20
a Yes ❑ No
10/12/20
/1 Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
29. User Name
1. Daimler Trucks NA, LLC 2.
3.
30. IUP Number
0001
31. Does File Contain Current Permit?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
32. Permit Expiration Date
6/30/25
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 to Permit Issue Date?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar
Year?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. AYes •No
b. •Yes •No
a. •Yes •No
b. •Yes •No
a. •Yes •No
b. •Yes •No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. AYes •No
b.❑Yes❑No®N/A
a. •Yes •No
b.❑Yes❑No❑N/A
a. •Yes •No
b.❑Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
❑ Yes /1 No
❑ Yes ❑ No
❑ Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
41a. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
❑Yes®No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
41b. During the Most Recent Semi -Annual Period, Did SIU submit all
reports on time?
❑Yes®No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
■ Yes •NoCNA
❑Yes❑No❑N/A
❑Yes❑No❑N/A
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑Yes®No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
c. Did POTW resample within 30 days of knowledge of SIU limit
violations from the POTW sample event?
a.❑Yes❑NoNN/A
b.❑Yes❑No®N/A
c ❑Yes❑NoNN/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
h.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes ao
❑ Yes ❑ No
❑ Yes ❑ No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
❑Yes®No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
47. Does the File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/AJ
48. Does The File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/AJ
49. 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
50. Did the POTW Representative Have Difficulty in Obtaining Any of
This Requested Information For You?
❑ Yes 0 No
❑ Yes ❑ No
❑ Yes ❑ No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

FILE REVIEW COMMENTS:
17. The POTW's WWTP exceeded the BOD weekly and monthly average limits in May 2019, June 2019 and August 2019. A weekly average
effluent BOD violation was also reported in July 2019. Effluent TS S weekly and monthly average violations and pH daily minimum violations
were reported in March 2020. A monthly average effluent fecal coliform violation was reported in July 2020 and weekly average effluent fecal
coliform violations were reported in August, September and November 2020. Inconsistent feed of sulfur dioxide was suspected for the BOD
violations. The fecal coliform violations were attributed to a chlorine contact chamber bypass valve not being completely closed. The sulfur
dioxide feed system has been serviced and the bypass valve has been closed.
22. The POTW will initiate sampling 18 months prior to the next HWA per Short Term Monitoring Plan (STMP). No STMP sampling has
been performed since the last Pretreatment Compliance Inspection.
35. The POTW performed the inspection at Daimler on 12/14/20.
36/37. Daimler's contacts listed in the slug/spill control plan and Toxic Organic Management Plan (TOMP) need to be updated.
39. The POTW contracts Pace Analytical Services to perform Industrial User Permit (IUP) analyses. The POTW failed to collect a pH sample
(according to the IUP) during the second half of 2020.
41a. Daimler contracts Pace Analytical Services to perform sample analyses. Daimler failed to monitor selenium, molybdenum and arsenic
(semi-annual monitoring) during the second half of 2020.
41b. Daimler failed to submit the TTO Certification by the IUP deadline (December 7); however, the TTO Certification was received by the
POTW on January 8, 2021. In addition, the TTO Certification did not cover the entire second half of 2020 (only December 2020). Note:
Daimler did not perform TTO sampling during the second half of 2020.
46. The POTW failed to initiate enforcement according to the Division approved Enforcement Response Plan (ERP) for the late submittal of
the TTO Certification and the failures to collect the semi-annual selenium, molybdenum and arsenic samples during the second half of 2020.
SUMMARY AND COMMENTS:
The POTW must ensure of the following: Division -approved ERP is properly initiated; IUP required detection levels are met by the contracted
lab; IUP monitoring is properly performed and slug/spill control plan and TOMP are reviewed and properly updated.
The POTW must initiate enforcement according to the Division -approved ERP for the late TTO Certification submittal and monitoring
violations within fourteen (14) days of receipt of inspection report.
The records reviewed during the inspection were organized and well maintained.
NOD: ❑ YES ® NO
NOV: ® YES ❑ NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
DocuSigned by:
PCI COMPLETED BY: L1V&J- Bat
DATE:
A61696D90CC3437...
Wes Bell, Sr. Environmental Specialist, Mooresville Regional Office
7/1/2021
DocuSigned by:
F14.14444, H Pa
PCI REVIEWED BY: F161FB69A2D84A3...
fo r
DATE:
7.1.21
W. Corey Basinger, Regional Supervisor, Mooresville Regional Office
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3