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HomeMy WebLinkAboutNC0049867_Inspection_20220614ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director The Honorable Patrick Phifer, Mayor Town of Cleveland 302 East Main Street Cleveland, North Carolina 27013 NORTH CAROLINA Environmental Quality June 14, 2022 SUBJECT: Pretreatment Compliance Inspection Town of Cleveland NPDES Permit No. NC0049867 Rowan County Dear Mayor Phifer: 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 14, 2022, by Mr. Wes Bell of this Office. Please advise the City's Pretreatment staff of our findings by forwarding the enclosed corrected report. Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at (704) 235-2192 or at wes.bell@ncdenr.gov. Enclosure: Inspection Report Cc: NPDES Program Files - Laserfiche DE 111.•rhworkt el G. rOrmloalal Oat,' Sincerely, DocuSigned by: A14CC681AF27425... W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources, NCDEQ w North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1610 East Center Avenue. Suite 301 1 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, Bryan Little 3. Title(s): Pretreatment Consultant, Town Commissioner 4. Last Inspection Date: 6/17/21 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 06/14/22 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? ❑ YES aO ❑ YES /1 NO Limits: None Reporting: None )lished: N/A N/A ❑ YES /1 NO 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 0 Yes ❑ No 1/28/19 0 Yes ❑ No 9/1/23 Industrial Waste Survey (IWS) 5/26/21 /1 Yes ❑ No 2/8/22 /1 Yes ❑ No 2/8/27 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) 9/2/20 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? /1 Yes ❑ 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❑NoON/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 @ No ❑ Yes ❑ No ❑ Yes ❑ No NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2 FILE REVIEW COMMENTS: 22. The POTW has not initiated sampling according to the Division -approved Short Term Monitoring Plan (STMP) since the last submittal of the Headworks Analysis (HWA) on 10/8/18. 35. The POTW performed the inspection at Daimler on 12/9/21. 37. Daimler has developed a Toxic Organic Management Plan (TOMP); however, semi-annual TTO sampling was performed in lieu of the Certification submittals. 39. The POTW contracts Pace Analytical Services to perform Industrial User Permit (IUP) sample analyses. 41a. Daimler contracts Pace Analytical Services to perform IUP sample analyses. SUMMARY AND COMMENTS: The POTW must ensure to initiate sampling according to the Division -approved STMP for the development of the HWA due 9/1/23. The records reviewed during the inspection were organized and well maintained. The POTW's Industrial Pretreatment Program was being properly implemented. NOD: ❑ YES ® NO NOV: ❑ YES ® NO QNCR: ❑ YES ® NO POTW Rating: Satisfactory ❑ Marginal ❑ Unsatisfactory ❑ PCI COMPLETED BY: PCI REVIEWED BY: ���D/ocuSignedeby: jOe . �J DATE: 6/14/2022 -A61696D9OCC3437... Wes Bell, Environmental Specialist II, MRO/WQROS, DWR DocuSigned by: A14CC681 AF27425... DATE: 6/14/2022 W. Corey Basinger, Regional Supervisor, MRO/WQROS, DWR NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3