NC0049867_Response to Notice_20231103

From: man Little
To: Bell, Wes
Subject: [External] NOV-2023-PC-0522
Date: Friday, November 3, 2023 10:48:09 AM
Attachments: 2023 PAI repsonse.doc
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Good Morning,
Here is the reply from the Town ref the above. If you have any questions, please feel
to contact myself.
Have a great weekend.
Bryan Little
Town of Cleveland
Pretreatment Coordinator
704-278-4777

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November 3, 2023
Wes Bell
NCDEQ-Division of Water Resources
REF: NOV-2023-PC-0522
Dear Mr. Bell,
The following is the Town of Cleveland's response to the above listed NOV.
All eDMRs (August 2022 — NIay 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.
Revision of the eDMR's has begun. The missed testing from the STMP will be filled in as the results become available.
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 I1, NPDES Permit and 40 CFR 403.12. All oil & grease samples (required grab samples) must be collected directly into
the sample container.
The Pretreatment and WWTP personnel have gone over the correct procedures for sampling. Due to an issue of misinformation
between the lab and the WWTP, errors occurred with certain sampling. This has been corrected on the Co Us.
All CoUs 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.
Retraining on the correct producer of filling out CoC's has been performed and for the foreseeable future, all CoC's will be double
checked by other Town personal prior to sending to Lab.
302 East Main Street, Cleveland, NC 27013
[phone]

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.
Due to an issue with training, testing per the STMP was missed. A review of the STMP has been made by the Town. A schedule for the
required testing has been implemented. This includes the lift stations, SUI and the WWTP. This schedule has been forwarded to the
lab in which the Town uses and has been imputed into their system.
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.
The Town has had an ongoing issue with information not being stored in the correct location. At the start of 2023, there was no
electronic backup of information for the Pretreatment Program. Town staff had started the implantation of an electronic backup
program prior to the PAI. Items are being scanned and stored in two locations. One is the Town's servers and a 2 Terabite external
hard drive. The hard drive will be stored in a secure location within Town Hall.
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.
The Town would like to thank the State in its recognition of the progress the Town has made in bringing the program back into
compliance and looks forward to ensure further progress is made.
Thank you,
Patrick Phifer, Mayor
Town of Cleveland.
302 East Main Street, Cleveland, NC 27013
[phone]

302 East Main Street, Cleveland, NC 27013
[phone]