NC0049867_Inspection_20231019

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
CERTIFIED MAIL#: 7020 3160 0000 3283 0670
RETURN RECEIPT REQUESTED
The Honorable Patrick Phifer, Mayor
Town of Cleveland
302 E. Main Street
Cleveland, NC 27013
Dear Mayor Phifer:
NORTH CAROLINA
Environmental Quality
October 19, 2023
SUBJECT: Notice of Violation
Pretreatment Audit Inspection
Town of Cleveland
NPDES Permit No. NCO049867
Rowan County
Tracking No. NOV-2023-PC-0522
Enclosed is a copy of the Pretreatment Audit Inspection (PAI) Report for the inspection of the Town of Cleveland's
Industrial Pretreatment Program on September 12, 2023, by Mr. Wes Bell of this Office.
This report is being issued as a Notice of Violation (NOV) due to the Town's failure to properly implement the
Pretreatment Program, violations of North Carolina General Statute (G.S.) 143-215.1, 15A North Carolina Administrative
Code (NCAC) 2H .0905, and the subject NPDES Permit. Specifically, the Town failed to do the following:
-Collect influent cyanide grab samples at the Town's wastewater treatment plant;
-Collect influent and effluent mercury samples as required by the Division -approved Short -Term Monitoring Plan
(STMP);
-Collect metals samples in the oxidation ditches as required by the Division -approved STMP;
-Report all effluent results on the eDMRs as a result of the STMP sampling events (August 2022 — May 2023);
-Collect required grab samples during a June 2023 sampling event at the Significant Industrial User (SIU);
-Maintain three years of all Pretreatment documentation (Program Elements info, SIU flow meter calibrations, etc.).
Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) per violation per
day, may be assessed 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
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
704.663.1699

The Town has requested extensions to the Division to allow time for staff to perform the required sampling (influent,
effluent and oxidation ditches) for the development of the Headworks Analysis. All eDMRs during the time period
STMP sampling was performed must be reviewed, revised and resubmitted to the Division by no later than February 1,
2024. It is requested that a written response be submitted to this Office by November 9, 2023, addressing the Town's
actions to prevent the recurrence of these violations.
If there are any questions concerning this report, please do not hesitate to contact Mr. Bell at [phone] or via
email at [e-mail].
Cc: NPDES Program Files - Laserfiche
Sincerely,
DocuSigned by:
A wNPuft
F161 F669A2D84A3...
Andrew H. Pitner, P.G.
Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality [ Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville. North Carolina 28115
704.663.1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Background Information
1. Control Authority (POTW) Name: Town of Cleveland
2. Control Authority Representative(s): Bryan Little
3. Title(s): Pretreatment Coordinator
4. Address of POTW:
Mailing: 302 East Main Street
City: Cleveland Zip Code: 27013
Phone Number [phone] Fax Number [phone] E-Mail blittle(d)townofclevelandnc.gov
5. Audit Date 09/12/2023
6. Last Inspection Date: 06/14/2022 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ❑ Yes ® No
If No, Explain. The Town has had to request extensions to the HWA submittal due to both incorrect sampling of
influent cyanide (composite samples collected and analyzed) and incomplete sampling of the influent and effluent
(for mercury) and oxidation ditches (metals) that is required by the Short -Term Monitoring Plan (STMP). The
new Pretreatment Coordinator is making progress to complete the above -noted sampling requirements.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ® Yes ❑ No
If Yes, Explain. Weekly Average effluent Fecal Coliform violation reported in October 2022.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number
INIC101014 I9 18 16 I7 I
MM/DD/YY
109 112 123
10.
.................................................................
Current Number of Significant Industrial Users(SIUs)?...............................................................................................
1
11.
..............................................................................
Number of SIUs with No IUP,..or with an Expired IUP?..............................................................................................................................
.....
0
12.
....................................................................................................................................................................................................................................................................................................
Number of SIUs Not Inspected by POTW in Last Calendar Year?
0
13.
....................................................................................................................................................................................................................................................................................................
Number of SIUs Not Sampled by POTW in Last Calendar Year?
1
14.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
0
15.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
0
16.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC with Pretreatment Schedule?
0
17.
....................................................................................................................................................................................................................................................................................................
Number of SIUs on Schedules?
0
18.
Current Number of Categorical Industrial Users..(CIUs)?............................................................................................
1
19.
Number of CIUs in SNC?
0
NC DWR Pretreatment Audit Form Revised: December 2016
Page 1

20. PRETREATMENT PROGRAM ELEMENTS REVIEW:
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
10/08/18
® Yes ❑ No
01/28/19
® Yes ❑ No
11/29/23*
Industrial Waste Survey (IWS)
05/26/21
® Yes ❑ No
02/08/22
® Yes ❑ No
02/08/27
Sewer Use Ordinance (SUO)
O1/18/13
® Yes ❑ No
01/23/13
® Yes ❑ No
Enforcement Response Plan (ERP)
02/12/20
® Yes ❑ No
02/14/20
® Yes ❑ No
Short Term Monitoring Plan (STMP)
09/02/20
® Yes ❑ No
10/12/20
® Yes ❑ No
Legal Authority (Sewer Use Ordinance-SUO)
21. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
❑ Yes ® No If yes, Please list these towns and/or areas.
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑ Yes ❑ No ®NA
A copy, if not already submitted, should be sent to Division.
23. If yes to #21, Have you had any trouble working with these towns or districts? ❑ Yes ❑ No ® NA
If yes, Explain.
24. Date of Last SUO Adoption by Local Council 11/06/2012
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? ❑ Yes ❑ No
If no, POTW must send copy within 30 days.
27. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
❑ Yes ® No If yes, Explain.
28. List Industries under a Schedule or Order and Type of Schedule or Order
N/A
Resources
29. 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 ❑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 DWR Pretreatment Audit Form Revised: December 2016 Page 2

30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Excell, MS Word
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
SIU is billed annually for costs associated with the Pretreatment Program (sampling, salary, etc.).
Public Perception/ Participation
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain.
33. Has any one from the public ever requested to review pretreatment program files? ❑ Yes ® No
If yes, Explain procedure. If no, how would the request be addressed? A request would be submitted in writing and files would
be reviewed at Town Hall with Town Clerk in attendance. It is recommended that the POTW develop a Standard
Operating Procedure (SOP) for all staff involved with the oversight of public requests to review Pretreatment Program
files.
34. Has any industry ever requested that certain information remain confidential from the public? ❑ Yes ® No If yes, Explain
procedure for determining whether information qualified for confidential status, as well as procedure for keeping files confidential
from public. If no how would the request be addressed? Town Commissioner and Pretreatment Coordinator would
review/approve request. Confidential files would be kept in a locked room/file cabinet. It is recommended that the POTW
develop a Standard Operating Procedure (SOP) for all staff involved with the oversight of public requests to review
Pretreatment Program files.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
37. Were all industries in SNC published in the last notice? ❑ Yes ❑ No ® N/A
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? Town Clerk and/or Planning/Zoning Committee
notifies the Pretreatment Coordinator of any new industries applying for sewer connection and any new business
licenses being granted.
39. Once the POTW becomes aware of new or changed Users, how does the POTW determine which industries have the
reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an
SIU?) Information on the IWS Short/Long forms are reviewed by Pretreatment Coordinator for any categorical
processes, POCs, flow volume, and organic loading.
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) POTW does not accept trucked waste.
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.)
N/A
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter 10%
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

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) IWS information, NPDES POCs,
categorical parameters, flow, and organic loading.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
New SIUs monitor monthly for base -line data, adjust monitoring to quarterly (at a minimum) based on the results.
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. Compliance Judgment Worksheet for SNC determinations,
Violations (limit, reporting, permit conditions) follow approved ERP.
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all Division data? ❑ Yes ❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes ❑ No
If no, Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
The current SIU and any new SIUs would be required to have a slug/spill control plan.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Emergency contacts kept up to date, on -site spill response equipment/materials, proper chemical storage/secondary
containment.
56. How does the POTW decide where the sample point for an SIU should be located?
The POTW currently samples the SIU's combined waste streams.
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. Contract lab performs sampling for SIU.
58. Who performs sample analysis for the POTW for
Metals Pace Analytical Services
Conventional Parameters Pace Analytical Services
Organics Pace Analytical Services
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
POTW and SIU use the contract lab's chain of custody forms.
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?
All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ❑ YES ® NO
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? McGill & Associates Phone [phone]
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
❑More LTMP data available ❑Resolve over allocation ®5 year expiration
EYES ❑ NO
❑NPDES limits change
❑ Other
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

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.
Summary
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.
3.
67. IUP Number
0001
68. Does File Contain Current Permit?
® Yes ❑ No
❑
Yes
❑
NoI
❑
Yes ❑ No
69. Permit Expiration Date
06/30/25
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 ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
73. a. Does File Contain 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
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Organic Management Plan (TOMP)?
75. a. Does File Contain Original Permit Review Letter from 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
76. During Most Recent Semi -Annual Period, Did POTW Complete its
® Yes ❑ No
❑Yes ❑ No
❑ Yes ❑ No
Sampling as Required b IUP, includingFlow?
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
®Yes❑No❑N/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
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
®Yes❑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❑NoON/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❑No❑N/A
P
❑ Yes El No
El Yes ❑ No
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Re ortin Non-Com liance from SIU Sampling?
83. a. Was POTW Notified by SILT (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. If applicable, did POTW resample and obtain results within 30 days of
c.❑Yes❑No®N/A
becomingaware of SIU limit violations in the POTW's sampling of SIU?
c.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑
Yes
®
No
❑
Yes
❑
No
❑
Yes
❑
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
®Yes❑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❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
88. a. Does File Contain Any Current Enforcement Orders?
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
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
® Yes ❑ No
❑ Yes ❑ No
❑ No
Information For You?
Ei
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

FILE REVIEW COMMENTS:
13. The POTW failed to perform the semi-annual sampling in 2022 at Daimler as required in the Industrial User Perimit (IUP). DWR
has previously addressed the POTW's failure to perform the required IUP sampling through the issuance of a NOV (dated 5/5/2023).
Note: The POTW will perform additional IUP sampling in 2023 to make up for the 2022 missed sampling events.
20. The Division approved a Headworks Analysis (HWA) extension to 11/29/2023. The Pretreatment Coordinator has submitted an
additional request to the Division to extend the HWA deadline to 2/29/2024.
60a. The POTW failed to collect influent and effluent mercury samples (at the wastewater treatment plant0 and selected metals in each
of the oxidation ditches in accordance with the Division approved Short Term Monitoring Plan (STMP). The influent cyanide samples
were also collected from the composite sample instead of being from a required grab sample.
60d. Most of the effluent metals results (STMP sampling events) were not reported on any of the eDMRs (August 2022 — May 2023).
The failure to report additional STMP effluent results on the eDMRs has been previously cited in the inspection report dated 7/3/2018.
72. The POTW inspected Daimler on 12/6/2022.
74. Daimler samples for the TTO parameters semi-annually.
76. The POTW collected composite cyanide and VOC samples (grab samples required) during the June 2023 IUP sampling event. The
POTW will perform additional cyanide and VOC grab samples to make up for the improperly sampled parameters.
77. The chain of custody (CoQ form for the March 2023 POTW sampling event was not completed properly. The POTW staff must ensure
all future CoCs have all parameters correctly listed with the appropriate sample type (composite or grab) and the applicable dates/times
samples were collected.
78. Daimler contracts Waypoint Analytical Services for sampling and analyses.
85. The POTW issued Daimler a NOV for BOD and TSS permit limit violations in March 2023. Note: Daimler is required to sample both
parameters monthly per IUP.
89. The POTW's Pretreatment Coordinator had difficulty retrieving all required Pretreatment documentation including flow meter
calibration records (Daimler) for the previous three years.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
�NIC10 10 14 19 18 16 17 0911212-3
1. Industry Inspected: Daimler Trucks North America, LLC
2. Industry Address: 11550 Statesville Blvd., Cleveland, N.C. 27013
3. Type of Industry/Product: Truck Manufacturing Plant/Metal Finisher
4. Industry Contact: Garrett Christy Title: Env. Engineer Phone: [phone]
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:
Daimler currently has three shifts consisting of full production (1st), paint and offline (2"d) and maintenance only (3rd). The facility
produces up to eight -one (81) trucks per day and employs approximately 2150 employees. The pretreatment system is staffed with
operators on all three shifts. Daimler's pretreatment system includes flow equalization, pH adjustment, flocculation, clarification, and
sludge filter press. Dewatered sludge is transported to the Covanta facility for incineration. Hazmat is contracted for spill cleanup.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6

AUDIT SUMMARY AND COMMENTS:
Requirements:
All eDMRs (August 2022 — May 2023) must be revised to include all effluent results from the STMP sampling events. In addition, all
transcription errors (incorrect sample type, units of measurement, effluent results, etc.) that were detected during the file review by DWR
staff must also be corrected prior to the submittal of the revised eDMRs.
The POTW staff must ensure that all samples are properly collected (STMP and/or IUP sampling events) in accordance with 40 CFR
136.3 Table II, NPDES Permit and 40 CFR 403.12. All oil & grease samples (required grab samples) must be collected directly into the
sample container.
All CoCs must be documented properly to show all sampled parameters, sample types (composite/grab), sampling dates/times and all
required preservatives (ice, chemical, etc.). The CoCs should also document dates/times samples were relinquished and received in the
contracted lab.
The POTW must also ensure that all sampling is performed at all locations and frequencies approved in the STMP prior to the
development and submittal of future HWAs.
All Pretreatment records must be kept for a minimum of three years and be available for inspection. The last approvals and supporting
documentation for Program Elements (HWA, SUO, Industrial Waste Survey, Enforcement Response Plan, etc.) and the previous IUP
should also be kept on file for review even if the documentation is older than three years.
Although several issues were noted during this Audit, the new Pretreatment Coordinator has made commendable progress in bringing
the POTW's Pretreatment Program back into compliance with all applicable requirements.
NOD: ❑ Yes
® No
NOV: ® Yes
❑ No
QNCR: ❑ Yes
® No
POTW Rating:
Satisfactory ❑
AUDIT COMPLETED BY:
Marginal
D/ocuSiiggnedd by:
WPiY YJEGG
A61696DWCC3437...
Unsatisfactory ❑
DATE: 10/18/2023
Wes Bell, Environmental Specialist II, DWR, WQROS, Mooresville Regional Office
[DocuSigned by:
A44" H P44-f4 10/18/2023
AUDIT REVIEWED BY: F161FB69A2D84A3... DATE:
Andrew H. Pitner, Regional Supervisor, DWR, WQROS, Mooresville Regional Office
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7