NC0049867_Industrial User_20180613

Lindsey Speed
DAIMLERSr.Environmental Engineer
Daimler Trucks North America LLC
11550 Statesville Boulevard
P.O.Box 399
Cleveland,NC 27013
704.645.5353 Phone
[e-mail]
June 13, 2018
Danny Gabriel
Mayor
Town of Cleveland
P.O. Box 429
Cleveland,NC 27013
HAND DELIVERED
SUBJECT: IUP PERMIT#0001 —Comments on Draft Permit Renewal
Mr. Gabriel:
I have received and reviewed the draft renewal of the Industrial User Permit for Daimler Trucks
North America LLC—Cleveland Truck Manufacturing Plant(Daimler),which was submitted to
me by email on June 11,2018. I appreciate the town's support in working together with Daimler
to provide a permit which will both protect the town's treatment system and is well suited for the
nature of our operations at Daimler.
Please find my comments written on the draft permit in Enclosure 1. I have also provided two
additional enclosures to help provide clarification on a couple of the comments on the draft
permit. Please let me know if any clarification is needed on any of these comments. I do
appreciate your consideration of these items.
Additionally,could you please provide me with written confirmation that Daimler's existing
permit(effective date May 1, 2017)will be administratively extended as we work through this
renewal process should the process extend beyond the expiration date of June 30,2018.
Sincerely, RECEIVED/DENR/DWR
6i/• peALLJUN 2 2 2018
Lindsey Speed Water Resources
Sr. Environmental Engineer Permitting Section
Enclosures:
Encl. 1 —Draft Permit—Comments
Encl. 2—NCDEQ Memo—Mercury Method 1361
End. 3—Monitoring Waiver Parameters Language
CC: Monti Hanson(Certified Mail 7007 3020 0002 3527 1968)

-- --
Industrial User Pretreatment Permit (IUP)
PART I - Specific Conditions
'b Y c0V1S I S'-Vt G ‘41/ CVt V'ra 1l— Town of Cleveland
trW lt k -t, n\J O(U c y a/ S,o v \ Control Authority and/or Municipality
4) ?.k vice yvur,n 1)4 CS PERMIT
Industrial User Pretreatment Permit(IUP)
To Discharge Wastewater Under the
op Industrial Pretreatment Program
—001-- 433.17
IUP Number 40 CFR Category(if Applicable)
In compliance with the provisions of North Carolina General Statute 143-215.1, any applicable federal
categorical pretreatment regulations, all other lawful standards and regulations promulgated and adopted
by the North Carolina Environmental Management Commission, and the Control Authority and/or
Municipality Sewer Use Ordinance. The following Industry hereafter, referred to by name or as the
Permittee:
Industry name, Permittee: Daimler Trucks North America,
LLC
Facility Located at Street Address 11550 Statesville Boulevard
City Cleveland
State,Zip NC 27013
is hereby authorized to discharge wastewater from the facility located at the above listed address into the
sanitary sewer collection system and the wastewater treatment facility of the Control Authority and/or
Municipality listed below:
IUP Control Authority and/or Municipality WWTP name: Town of Cleveland WWTP
NPDES Number: NC0049867
WWTP Address: 625 Third Creek Church Road
City, State,Zip Cleveland,NC 27013
in accordance with effluent limitations,monitoring requirements,and all other conditions set forth in Parts
I, II, and III of this Industrial User Pretreatment Permit(IUP).
Effective date,this permit and the authorization to discharge shall
become effective at 12:01 am on this date:
July 1, 2018
Expiration date,this permit and the authorization to discharge shall
expire at midnight on this date:
June 30, 2020
Date signed Mayor, Town of Cleveland
2 '

Industrial User Pretreatment Permit (IUP)
PART I - Specific Conditions
IUP, PART I, OUTLINE:
A.) IUP Basic Information
B.) IUP Modification History
C.) Authorization Statement
D.) Description of Discharges
E.) Schematic and Monitoring Locations
F.) Effluent Limits &Monitoring Requirements
G.) Definitions and Limit Page(s)notes
A. IUP Basic Information:
Receiving Control Authority&W WTP name: POTW NPDES#:
' Town of Cleveland WWTP NC0049867
l
IUP Name: [UP Number:
Daimler Trucks North America,LLC —001 `
QOO I
IUP Effective date: Pipe Numbers,list all regulated pipes:
July 1,2018 001 and 002
[UP Expiration date: IUP 40 CFR#(if applicable),or N/A:
June 30,2020 433.17
B. IUP History. A Complete Permit History is required
Effective Renewal or Description of changes over previous IUP.
Date Modification
5/1/1995 Issued First Issued IUP � �
1995- See attachment Part I B. IUP History �0
rit
1 2017. Y1f1\Ss X119
Modification Definition of Daily
6/30/2018 Renewal Monitoring waiver for metals
BOD and TSS changed to pounds per day rather than concentration
limit.
3

Industrial User Pretreatment Permit (IUP)
PART I - Specific Conditions
C.) Authorization Statement:
1.) The Permittee is hereby authorized to discharge wastewater in accordance with the effluent
limitations, monitoring requirements, and all other conditions set forth in this Industrial User
Pretreatment Permit (IUP) into the sewer collection system and wastewater treatment facility
of the Control Authority and/or Municipality.
2.) The Permittee is hereby authorized to continue operation of and discharge wastewater from the
following treatment or pretreatment facilities. These facilities must correspond to the treatment
units listed on both the application and inspection forms.
IU Treatment Units
Pipe 001 Process wastewater
List all Treatment List all Treatment Units:
Units: Two 10,000 gallon tanks
Flow Equalization Two 1000 gallon reaction tanks and
Chemical Two 600 gallon neutralization tanks for metals removal. Polymers
Precipitation, and coagulant added to precipitate the separation of liquids and solids.
flocculation, and
Caustic and sulfuric acid to adjust the pH during this process.
coagulation, e ing and Solids Removal
2000 gallon sludge holding tank
Plate and frame press, cake disposal t hazardous wast
Clarification
Sludge Tank Trapezoidal flume with ISCO bubbler fl recorder and totalizer and
Sludge Handling refrigerated flow proportioned sampler
incl pH adjustment No 1 n h 9 Ivrt
Flow meter and -9 p C��t d �
�� l
sampler equipment �/�J�,,S�G
On 21aordatnct
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WenCIVO 1( �'c tl�o ad t W dur1r .e "kYtatrnenf
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C ----___ Industrial User Pretreatment Permit (IUP)
PART I - Specific Conditions
CAVI IX
Pipe Water from each dry filter paint booth cleaning-is-pumped into a vac
Dry filter paint boo and-tank filtered through a coarse mesh filter into a sanitary sewer
Wash water filtering manhole. Each cleaning produces about 3,000 gallons of wastewater
process and there are six dry filter paint booths.
Throughout the production area and discharge to the sanitary sewer system
Oil/Water Separators These are maintained on a quarterly basis.
Monitoring and Sampling
8 inch trapezoidal flume in manhole located near rear fence ISCO
bubbler pe flow meter recorder and totalizer and refrigerated flow
proportional sampler.
UlkrzonIG
3.) The Permittee is hereby authorized to,if required by the Control Authority and/or Municipality
and after receiving Authorization to Construct (A to C) from the Control Authority and/or
Municipality, construct and operate additional pretreatment units as needed to meet final
effluent limitations. ``
D.) Description of IUP Discharge(s): w
1. Describe the discharge(s) from all regulated pipes.
?
Pipe# 001 , Process wastewater regulated by 40 CFR 433.17: .%4 '
All process wastewaters from metal finishing operations, fiberglass 0. kt
hood wash and fiberglass top wash and fairings wash. ( _4
`_ r
Pipe#002 � '‘
Flow from Pipe #001 and all domestic wastewater from Daimler
buildings,non-contact cooling tower blow down watery paint filte
booth wash (x6) and chassis wash wateJ
5

Industrial User Pretreatment Permit (IUP)
PART I - Specific Conditions
E.) Schematic and Monitoring Locations:
The facility schematic and description of monitoring location(s) given below must show enough
detail such that someone unfamiliar with the facility could readily find and identify the monitoring
location(s) and connection to the sewer. Include and identify all regulated pipes.
Attachment to Permit
Submitted flow diagram from Daimler Application
6

Industrial User Pretreatment Permit (IUP)
PART I - Specific Conditions
IUP, Part 1 Section F: Receiving POTW name—> v1wTP Cleveland
Effluent Limits and Monitoring
Requirements Receiving POTW NPDES#=>NC0049867
Effective date for these Limits=>7/1/2018
Expiration date for these Limits=>6/30/2020
The Permittee may discharge from this Daimler Trucks
specific Pipe number according to these rU name=>NA,LLC
specific dates, effluent limits, and IUP#=>001 1
monitoring requirements Pipe#=>002
40 CFR#=>433.17
4mve At, MAW() VA1S'Ii1n9
Ornfi
Parameters Concentration Limits Monitoring Frequency i
Sample • •
1 Collection •• • •
Monthly . Method Detection 1
1Z3—
Daily Max Average Units By Industry By POTW (C or G) Level 4.4
1 0.200 0.175 MGD Continuous/ Every sample* i Meter * tr
Flow Daily * 4.
2 pH :.! :.•
6.0-10.0 SU Production Daily Once/6 months , G 0
3 Oil&Grease 100 100 Mg/1 1/month Once/6months G 5 o
4 NH3-N 120 75 Mg/I 1/month Once/6 months C 0
5 Aluminum * Mg/1 Monthly Once/6month C 0
6 Arsenic * Mg/I Once gees yr Once/6months C 0.005
7 Cadmium Mg/1 I Once/6 Months I C 0.002 S i E
8 Chromium Mg/1 Once/6 Months C 0.005
9 Copper 1.27 0.78 Mg/1 Monthly Once/6 Months C 0.002 0 s
10 Cyanide Mg/1 Once/6 Months , G 0.01
11 Lead Mg/I Once/6 Months C 0.0 .")
12 Mercury ** Ng/1 Once/6-nmtnhS r Once/6 Months Grab** 4 1 ng/1**
y J
13 Mol bdenum * Mg/I Once/6saer►drs Once/6months C 0.005
14 Nickel _ _ Mg/I Once/6 Months C 0.01
15 Selenium * Mg/I Once16mendhs lar Once/6 Months C 0.05
16 Silver 1 Mg/1 J Once/6 Months C 0.005
17 Zinc .9834 .557 Mg/I Monthly Once./6 Months C 0.01
18 TTO *** 0.8026 Mg/1 Once/6 Months Once/year*** G 0.01
***
19 COD * Mg/I Monthly once/6months C 25
20 BOD 407 270 #/day Monthly Once/6months C 2
21 TSS 375 250 #/day Monthly Once/6months C 5
22 MBAS 7.5 3.5 Mg/1 Monthly Once/6months Grab
*See Part I,G,3 and 4, and III,3
** See Part I,G,7
*** See Part III, 6-8
7

Industrial User Pretreatment Permit (IUP)
PART I - Specific Conditions
IUP, Part 1 Section F: Cleveland
Effluent Limits and Monitoring Receiving POTW name=> ,``,Ip
Requirements Receiving POTW NPDES#=>NC0049867
Effective date for these Limits=>7/1/2018
The Permittee may discharge from this Expiration date for these Limits=>6/30/2020
specific Pipe number according to these Hi name=>Daimler
A,LLC Trucks
specific dates, effluent limits, and IUP#=>001
monitoring requirements Pipe#_>001
40 CFR#=>433.17
Flow shall be reported daily for process flows that are classified as categorical each
production day and continuous recording for monthly totals.
G:low meter shall be calibrated at a minimum annually and documentation submitted to the
POTW-.3
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be, &u\m t-ed?
douurn,e+r�m°'�
G.) Definitions and Limit Page(s) notes:
In addition to the definitions in the Town of Cleveland Sewer Use Ordinance the following
definitions and requirements apply:
1. Composite Sample:
Unless defined differently below, a composite sample for the monitoring requirements of
this IUP is defined as the automatic or manual collection of one grab sample of constant
volume, not less than 100 ml, collected every hour during the entire discharge period on
the sampling day and proportioned for flow. Sampling day shall be a typical production,
and discharge day.
8

Industrial User Pretreatment Permit (IUP)
PART I - Specific Conditions
2. Daily Monitoring Frequency
Daily Monitoring Frequency as specified in this IUP shall mean each day of discharge that
is classified as categorical.
A
3. Continuous/Daily Monitoring Frequency
For flow, "continuous" refers to the requirement to use a continuous recording discharge
flow meter. See Part III, 3 for more details. For flow, "daily" shall mean the Permittee
shall read the flow meter totalizer every day, including weekends and holidays, convert
this to a daily flow, and report these daily flows to the Control Authority with the report
�.. due under Part II, 2.
's
d C.4.D "Every Sample" Monitoring Frequency
A Monitoring Frequency of"every sample" as specified in this IUP shall mean each time
S a composite or grab sample is collected.
5. Grab Sample
4.3
Grab sample for the monitoring requirements of this IUP, is defined as a single "dip and
Z • take" sample collected at a representative point in the discharge stream.
11
Instantaneous measurement
An Instantaneous measurement for the monitoring requirements of this IUP is defined as a
single reading, observation, or measurement.
7. Mercury Sampling and Analysis
The Permittee shall analyze for mercury using EPA Method 1631, and shall use Method
1669 Clean Sampling Techniques as needed to maintain acceptable blanks.
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ut r�mc n-f' ebr Me#1 oa l b3
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Set � A M
9

Industrial User Pretreatment Permit (IUP)
PART II
Generic Conditions
Outline of PART II,
1. Representative Sampling 16. Federal and/or State Laws
2. Reporting 17. Penalties
3. Test Procedures 18. Need to Halt or Reduce
4. Additional Monitoring by Permittee 19. Transferability
5. Duty to comply 20. Property Rights
6. Duty to Mitigate 21. Severability
7. Facilities Operation, Bypass 22. Modification, Revocation, Termination
8. Removed substances 23. Reapplication
9. Upset Conditions 24. Dilution Prohibition
10. Right of Entry 25. Reports of Changed Conditions
11. Availability of Records 26. Construction of pretreatment facilities
12. Duty to provide information 27. Reopener
ato Requirements 28. Categorical Reopener
13. Signatory g
14. Toxic Pollutants 29. General Prohibitive Standards
15. Civil and Criminal Liability 30. Reports of Potential Problems
1. Representative Sampling
Samples and measurements taken as required herein shall be representative of the volume and nature of the
monitored discharge. All samples shall be taken at the monitoring points specified in this permit and,unless
otherwise specified, before the effluent joins or is diluted by any other wastestream, body of water, or
substance. Monitoring points shall not be changed without notification to, and approval by, the permit
issuing authority.
2. Reporting
a.) Monitoring results obtained by the permittee shall be reported on forms specified by the Control
Authority and/or Municipality,postmarked no later than the twentieth day of the month following
the month in which the samples were taken. If no discharge occurs during a reporting period(herein
defined as each calendar month) in which a sampling event was to have occurred, a form with the
phrase"no discharge"shall be submitted. Copies of these and all other reports required herein shall
be submitted to the Control Authority and/or Municipality and shall be sent to the following
address:
Town of Cleveland
Pretreatment Coordinator
Post Office Box 429
Cleveland,NC 27013
b.) If the sampling performed by the permittee indicates a violation,the permittee shall notify the Control
Authority and/or Municipality within 24 hours of becoming aware of the violation. The permittee shall
also repeat the sampling and analysis and submit the results of the repeat analysis to the Control
Authority and/or Municipality within 30 days after becoming aware of the violation.
10

Industrial User Pretreatment Permit (IUP)
PART II
Generic Conditions
3. Test Procedures
Test procedures for the analysis of pollutants shall be performed in accordance with the techniques
prescribed in 40 CFR part 136 and amendments thereto unless specified otherwise in the monitoring
conditions of this permit.
4. Additional Monitoring by Permittee
If the permittee monitors any pollutant at the location(s) designated herein more frequently than required
by this permit, using approved analytical methods as specified above, the results of such monitoring shall
be submitted to the Control Authority and/or Municipality. The Control Authority and/or Municipality
may require more frequent monitoring or the monitoring of other pollutants not required in this permit by
written notification.
5. Duty to Comply
The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a
violation of the Control Authority and/or Municipality Sewer Use Ordinance and is grounds for possible
enforcement action.
6. Duty to Mitigate - Prevention of Adverse Impact
The Permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this permit
which has a reasonable likelihood of adversely affecting human health,the POTW,the waters receiving the
POTW's discharge, or the environment.
Facilities Operation, Bypass
p
The permittee shall at all times maintain in good working order and operate as efficiently as possible, all
control facilities or systems installed or used by the permittee to achieve compliance with the terms and
conditions of this permit. Bypass of treatment facilities is prohibited except when approved in advance by
the Control Authority and/or Municipality. Bypass approval shall be given only when such bypass is in
compliance with 40 CFR 403.17.
8. Removed Substances
Solids, sludge, filter backwash, or other pollutants removed in the course of treatment or control of
wastewaters shall be disposed of in a manner such as to prevent any pollutants from such materials from
entering the sewer system. The permittee is responsible for assuring its compliance with any requirements
regarding the generation, treatment, storage, and/or disposal of"Hazardous waste" as defined under the
Federal Resource Conservation and Recovery Act.
9. Upset Conditions
An "upset" means an exceptional incident in which there is an unintentional and temporary noncompliance
with the effluent limitations of this permit because of factors beyond the reasonable control of the permittee.
An upset does not include noncompliance to the extent caused by operational error, improperly designed
or inadequate treatment facilities,lack of preventative maintenance, or careless or improper operations.
An upset may constitute an affirmative defense for action brought for the noncompliance. The permittee
has the burden of proof to provide evidence and demonstrate that none of the factors specifically listed
above were responsible for the noncompliance.
11

Industrial User Pretreatment Permit (IUP)
PART II
Generic Conditions
10. Right of Entry
The permittee shall allow the staff of the State of North Carolina Department of Environment and Natural
Resources, Division of Water Resources, the Regional Administrator of the Environmental Protection
Agency, the Control Authority and/or Municipality, and/or their authorized representatives, upon the
presentation of credentials:
1. To enter upon the Permittee's premises where a real or potential discharge is located or in which
records are required to be kept under the terms and conditions of this permit; and
2. At reasonable times to have access to and copy records required to be kept under the terms and
conditions of this permit;to inspect any monitoring equipment or monitoring method required in
this permit; and to sample any discharge of pollutants.
11. Availability of Records and Reports
The permittee shall retain records of all monitoring information, including all calibration and maintenance
records as well as copies of reports and information used to complete the application for this permit for at
least three years. All records that pertain to matters that are subject to any type of enforcement action shall
be retained and preserved by the permittee until all enforcement activities have concluded and all periods
of limitation with respect to any and all appeals have expired.
Except for data determined to be confidential under the Sewer Use Ordinance, all reports prepared in
accordance with terms of this permit shall be available for public inspection at the Control Authority and/or
Municipality. As required by the Sewer Use Ordinance, effluent data shall not be considered confidential.
12. Duty to Provide Information
The permittee shall furnish to the Director of Public Works or his/her designees,within a reasonable time,
any information which the Director, his/her designee, or the Division of Water Resources may request to
determine whether cause exists for modifying, revoking and reissuing, or terminating this permit or to
determine compliance with this permit. The permittee shall also furnish, upon request, copies of records
required to be kept by this permit.
13. Signatory Requirements
All reports or information submitted pursuant to the requirements of this permit must be signed and certified
by the Authorized Representative as defined under the Sewer Use Ordinance. If the designation of an
Authorized Representative is no longer accurate because a different individual or position has responsibility
for the overall operation of the facility,or overall responsibility for environmental matters for the company,
a new authorization satisfying the requirements of this section must be submitted to the POTW Director
prior to or together with any reports to be signed by an authorized representative.
14. Toxic Pollutants
If a toxic effluent standard or prohibition(including any schedule of compliance specified in such effluent
standard or prohibition) is established under Section 307(a) of the Federal Clean Water Act for a toxic
pollutant which is present in the discharge and such standard or prohibition is more stringent than any
limitation for such pollutant in this permit, this permit may be revised or modified in accordance with the
toxic effluent standard or prohibition and the permittee so notified.
12

Industrial User Pretreatment Permit (IUP)
PART II
Generic Conditions
15. Civil and Criminal Liability
Nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties for
noncompliance.
16. Federal and/or State Laws
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the
permittee from any responsibilities, liabilities, or penalties established pursuant to any applicable Federal
and/or State law or regulation.
17. Penalties
The Sewer Use Ordinance of the Control Authority and/or Municipality provides that any person who
violates a permit condition is subject to a civil penalty not to exceed $25,000 dollars per day of such
violation.
Under state law,(NCGS 143-215.6B),under certain circumstances it is a crime to violate terms,conditions,
or requirements of pretreatment permits. It is a crime to knowingly make any false statement,
representation, or certification in any record or other document submitted or required to be maintained
under this permit, including monitoring reports or reports of compliance or noncompliance. These crimes
are enforced at the prosecutorial discretion of the local District Attorney.
18. Need to Halt or Reduce not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt
or reduce the permitted activity to maintain compliance with the conditions of the permit.
19. Transferability
This permit shall not be reassigned or transferred or sold to a new owner, new user, different premises, or
a new or changed operation without approval of the Town.
20. Property Rights
This permit does not convey any property rights in either real or personal property, or any exclusive
privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any
infringement of Federal, State or local laws or regulations.
21. Severability
The provisions of this permit are severable and, if any provision of this permit or the application of any
provision of this permit to any circumstance is held invalid, the application of such provision to other
circumstances and the remainder of this permit shall not be affected thereby.
22. Permit Modification, Revocation, Termination
This permit may be modified, revoked and reissued or terminated with cause in accordance to the
requirements of the Control Authority and/or Municipality Sewer Use Ordinance and North Carolina
General Statute or implementing regulations.
23. Re-Application for Permit Renewal
The permittee is responsible for filing an application for reissuance of this permit at least 180 days prior to
its expiration date.
13

Industrial User Pretreatment Permit (IUP)
PART II
Generic Conditions
24. Dilution Prohibition
The permittee shall not increase the use of potable or process water or in any other way attempt to dilute
the discharge as a partial or complete substitute for adequate treatment to achieve compliance with the
limitations contained in this permit.
25. Reports of Changed Conditions
The Permittee shall give notice to the Control Authority and/or Municipality of any planned significant
changes to the Permittee's operations or system which might alter the nature, quality, or volume of its
wastewater at least 180 days before the change. The permittee shall not begin the changes until receiving
written approval from the Control Authority and/or Municipality. Also see Part II, 30 below for additional
reporting requirements for spill/slug issues.
Significant changes may include but are not limited to
(a) increases or decreases to production;
(b) increases in discharge of previously reported pollutants;
(c) discharge of pollutants not previously reported to the Control Authority and/or Municipality;
fa...,. --(e)— new or changed manufacturing processes and/or chemicals; or
c,V1wh W arc.
[lnc siiio v L f e rev w }3 }cA "+Nor otliwi G t 1 k-crit, au:vac er►5.tic s
26. Construction � &c�u �'�
No construction of pretreatment facilities or additions thereto shall be begun until Final Plans and
Specifications have been submitted to the Control Authority and/or Municipality and written approval and
an Authorization to Construct(A to C)have been issued.
27. Reopener
The permit shall be modified or,alternatively,revoked and reissued to comply with any applicable effluent
standard or limitation for the control of any pollutant shown to contribute to toxicity of the WWTP effluent
or any pollutant that is otherwise limited by the POTW discharge permit. The permit as modified or
reissued under this paragraph may also contain any other requirements of State or Federal pretreatment
regulations then applicable.
28. Categorical Reopener
This permit shall be modified,or alternatively,revoked and reissued,to comply with any applicable effluent
standard or limitation issued or approved under Sections 302(bX2)(C)and(D),304(b)(2),and 307(a)(2)of
the Clean Water Act, if the effluent standard or limitation so issued or approved:
1.) Contains different conditions or is otherwise more stringent than any effluent limitation in
this permit; or
2.) Controls any pollutant not limited in this permit.
The permit as modified or reissued under this paragraph shall also contain any other requirements of the
Act then applicable.
14 1

Industrial User Pretreatment Permit (IUP)
PART II
Generic Conditions
29. General Prohibitive Standards
The permittee shall comply with the general prohibitive discharge standards in 40 CFR 403.5 (a)and(b)of
the Federal pretreatment regulations.
30. Potential Problems
The Permittee shall provide protection from accidental and slug discharges of prohibited materials and other
substances regulated by this permit. The permittee shall also notify the POTW immediately of any changes
at its facility affecting the potential for spills and other accidental discharge, discharge of a non-routine,
episodic nature,a non-customary batch discharge,or a slug load as defined in the Sewer Use Ordinance.
Additionally, the Permittee shall notify by telephone the Control Authority and/or Municipality
immediately of all discharges that could cause problems to the POTW including any slug loadings as
defined in the Sewer Use Ordinance. If the permittee experiences such a discharge, they shall inform the
Control Authority and/or Municipality immediately upon the first awareness of the commencement of the
discharge. Notification shall include location of the discharge,type of waste, concentration and volume if
known and corrective actions taken by the permittee. A written follow-up report thereof shall be filed by
the permittee within five(5) days,unless waived by the Control Authority and/or Municipality.
15

Industrial User Pretreatment Permit (IUP)
PART III
Special Conditions
1. Slug/Spill Control Plan
In addition to the requirements in Part II, 30, the Permittee shall complete installation and/or commence
implementation, operation, and/or maintenance of the following specific protection Measures, Activities,
Plans. Etc. (Items without specific completion date, or marked as "Continuous." must be performed for
the entire duration of the permit):
Required
Completion/
Description of Measure, Activity,Plan, etc. Implementation Date
1. Submit Slug/Spill Control Plan in accordance with SUO 10/2010
[Section 2.8(c)]; Implement Upon POTW Approval
The Permittee shall provide updates to the Control Authority as required by Part II, 30,of this IUP.
Modifications to the measures shall be approved by the Control Authority prior to
installation/implementation. If a measure fails, the Control Authority shall be notified within 24
hours.
2. Sludge Management Plan
Ninety days prior to the initial disposal of sludge generated by any pretreatment facility, the
permittee shall submit a sludge management plan to the Control Authority.
3. Flow Measurement Requirements
The Permittee shall maintain appropriate discharge flow measurement devices and methods
consistent with approved scientific practices to ensure the accuracy and reliability of measurements
of the volume of monitored discharges. Devices installed shall be a continuous recording flow
meter capable of measuring flows with a maximum deviation of less than 10% from true discharge
rates throughout the range of expected discharge volumes. The totalizer shall be non-
resettleable. The devices shall be installed,calibrated, and maintained to ensure accuracy. At the
time of issuance of the permit, this method consists of bubbler flow meter at sample point for
Pipe 002. The meter shall be calibrated every year. Modifications to the flow metering equipment
shall be approved by the Control Authority prior to installation. If a required flow measurement
device fails, the Control Authority shall be notified within 24 hours.
4. Certified Laboratory Analysis
Pollutant analysis shall be performed by a North Carolina Division of Water Resources Certified
Laboratory that is certified in the analysis of the pollutant in wastewater.
5. Certified Operator
Pursuant to Chapter 90A-44 of North Carolina General Statutes, and upon classification of the
facility by the Certification Commission, the permittee shall employ a certified wastewater
pretreatment plant operator in responsible charge (ORC) of the wastewater treatment facilities.
Such operator must hold a certification of the type and grade equivalent to, or greater than the
classification assigned to the wastewater treatment facilities by the Certification Commission. The
16

Industrial User Pretreatment Permit (IUP)
PART III
Special Conditions
permittee must also employ a certified backup operator of the appropriate type and grade to comply
with the conditions of Title 15A, Chapter 8A .0202. The ORC of the facility must visit the
wastewater facility as required; must properly manage and document daily operation and
maintenance of the facility; and must comply with all other conditions of Title 15A, Chapter 8A
.0202. The permittee shall submit a letter designating the operator in responsible charge to the
Certification Commission or their designee within thirty days after facility classification.
Until the above certified operator requirements come into effect, the Permittee shall at all times
have appropriately trained operators capable of properly operating all units. Permittee shall notify
POTW of designated operators including credentials, within 24 hours of staff change.
§D GOoSicteIra t'+or it oncrciiStn
6. Total Toxic Organics (TTO) Defmition
l0 3b da�S?
"TTO", or Total Toxic Organics, is the sum of the concentrations of the toxic organic compounds
listed in 40 CFR 433.11 (e) that are found in the Permittee's process discharge at a concentration
greater than 0.01 mg/l.
7. Total Toxic Organics (TTO) Certification
In lieu of monitoring for TTO, the Permittee may, upon submitting to the Control Authority one
sample showing TTO compliance and a Toxic Organic Management Plan, make the following
certification every six months:
"Based upon my inquiry of the person or persons directly responsible for managing compliance
with the permit limitation for total toxic organics (TTO), I certify that, to the best of my
knowledge,no dumping of concentrated toxic organics into the wastewaters has occurred since
filing of the last monitoring report. I further certify that this facility is implementing the toxic
organic management plan submitted to the Control Authority."
At a minimum, the certification statements are due by June 30 of each year covering the January
through June six month period, and December 7 of each year covering the July through December
six month reporting period. If the certification is not submitted for both periods within 7 days of
the respective due dates,the Control Authority shall collect TTO samples before December 31 and
the Permittee may be billed for the cost of the TTO sampling and/or analysis.
8. Toxic Organic Management Plan
Within ninety days of the issuance of this permit, the Permittee shall develop and submit to the
Control Authority a toxic organic management plan.
9. Combined Wastestream Formula Flow Condition
Regulated Categorical Process Flow:
The Permittee shall have available flow monitoring equipment at such locations as necessary to
measure the total daily volume of wastewater discharged that is covered by 40 CFR 403.6 (e).
This flow monitoring equipment shall also be capable of measuring flows with a maximum
deviation of less than 10% from true discharge rates throughout the range of expected discharge
volumes. At the time of issuance of the permit,this method consists of a flume and . •ubble ow
17 WY*a.551

Industrial User Pretreatment Permit (IUP)
PART III
Special Conditions
meter. Data shall be collected and reported as required in Part II, 1-4 of this IUP. Modifications
to the flow metering equipment shall be approved by the Control Authority prior to installation.
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18

IUP Synopsis
A. IUP Basic Information
Receiving POTW name: POTW NPDES#:
Town of Cleveland WWTP NC0049867
IUP name IUP Number.
Daimler Trucks North America,LLC ---00}- 1
IUP Effective date: Pipe Numbers,list all regulated pipes:
July 1,2018 001 and 002
IUP expiration date: IUP 40 CFR#,if applicable:
June 30,2020 433.17
B. IUP Survey & Application form
I Attach a completed copy of the Industrial User Wastewater Survey & Application Form(see
appendix 6-A) submitted with application December 2017
C. IU Inspection form
Attach a copy of an Industrial User Inspection Form(see chapter 7) completed by the Control
Authority within the past 12 months.
Completed by Heather Adams from Envirolink on 11/21/2017
D. RATIONALE FOR LIMITATIONS:
As listed on the IUP Limits Page(s), PART I, Section F of the IUP.
Parameters Concentration Limits
Monthly Limits
Daily Max Average Units Regulated by
Flow 0.195 0.175 MGD Local Limit
6.0-10.0 SU Local Limit , (}Qf�
pH ` I
Cadmium m• aivedopoor.y � v�.�
Chromium mg/I �waiv W
Copper 1.741 mg/lC____, Y\ "Cyanide mg/1E r (k . �r
Lead mg/IEDNickel mg/1ED � \ lSilver mg/1ED
Zinc 1.245 mgt CWF
TTO *** 1.792 mg/1 CWF
OIL&GREASE 100 100 Mg/1 Local Limit
NH3-N 120 75 Mg/1 Local limit
BOD 407 270 #/day HWA
TSS 375 250 #/day HWA
COD Mg/1
MBAS 7.5 3.5 Mg/1 Local limit
RATIONALE#1:
Review of IU Monitoring Data, with no Over Allocation situation:
1

IUP Synopsis
The following pollutants were assigned numerical limits in this IUP based on a review of monitoring
data for the permittee to determine what ranges of concentrations are currently being discharged. To
account for sample variability a factor was applied to the monitoring data to determine the permit
limit. Permit limits assigned by the Local IUP Control Authority can not result in an Over Allocation
situation for any pollutants.
RATIONALE#2:
Categorical Industrial Limits, with no Over Allocation situation:
Check here if Combined Wastestream Formula(CWF) or other categorical limits calculations were
used. If used, Please attach calculations: (see CWF Spreadsheet, Appendix 6-F)
Were used (attach calculations) X
Were not used
The Combined Wastestream Formula was used to determine categorical pretreatment limits.
Total Regulated Wastestream = 26,000 gpd = Process flow + Contact cooling + Process Related
Washdown
Total Unregulated Wastestream =
Total Diluted Wastestream =43000 gpd=Non-contact cooling+Boiler blowdown+Domestic
Total Wastestream= 69,000 gpd
Combined Wastestream Formula= (Total Regulated + Total Unregulated)/Total Wastestream
CWF = (26000)/69000 = 0.3768
Combined Wastestream Formula
Industry: Daimler -433.17
IUP # : 001
Date: 06/02/2018
CWF Rath
Regulated Unregulated Diluted TORI (Regulated
Wastestream
gpd Wastestream gpd Wastestream gpd Wastestream Unregulated
(gPd) otal Flow
Process Flow 26000 Non-contact Cooling
Process Contact Domestic 43000
Cooling water
Process Related Boiler Blowdown
Washdown
Total 26000 0 43000 69000 0.377
**Contains high levels of several metals, POTW approved as"unregulated" under 403.6(e)
2

IUP Synopsis
List All Listed Listed CWF CWF
Applicable Categorical Categorical Adjusted Adjusted Current Proposed
Catergorical Daily Monthly Daily Monthly Limit Daily Limit Daily
Limited Maximum Average Maximum Average Max(mg/1) Max(mg/I)
Parameters Limit(mg/I) Limt(mg/1) Limit(mg/I) (mg/1)
Cadmium 0.11 0.07 0.093 0.059 0.07 0.059
Chromium 2.77 1.71 2.330 1.439 1.71 1.439
Copper 3.38 2.07 2.843 1.741 2.07 1.741
Lead 0.69 0.43 0.580 0.362 0.43 0.362
Nickel 3.98 2.38 3.348 2.002 2.38 2.002
Silver 0.43 0.24 0.362 0.202 0.24 0.202
Zinc 2.61 1.48 2.196 1.245 1.48 1.245
Cyanide 1.2 0.65 1.010 0.547 0.01 0.010
ITO 2.13 1.792 2.13 1.792
The following pollutants were assigned numerical limits in this IUP based on the categorical
regulations. These limits do not result in over allocations.
Cu, Zn,TTO
RATIONALE#3a:
Over Allocation Prevention, with IU pollutant reduction:
The following pollutants were assigned numerical limits in this IUP based on allocating the
Maximum Allowable Industrial Loading (MAIL) determined with the Headworks Analysis (HWA)
among all Industrial Users. The total loading of each pollutant from all permitted discharges does
not exceed the MAIL. These limits do
not result on over allocations.
3 N/A _
RATIONALE#3b:
Interim Limits for IU pollutant reduction:
The following pollutants were assigned interim numerical limits in this IUP to allow time for the
industry to come compliance with final limits that will not in over allocations.
N/A ---
RATIONALE#4:
Other Rationale for Limitations:
The following rationale was used for developing IUP Limits.
3

IUP Synopsis
Parameter Rationale
BOD, TSS ALLOCATION BASED ON
HISTORICAL DATA
RATIONALE#5a:
Non-Categorical Parameters where No Limit needed or assigned in an IUP:
The following pollutants were not assigned numerical limits in this IUP because the loadings for
these pollutants from this IU were less than 5% of the MARL, or were greater than 5% MAHL but
WWTP has significant available capacity (average influent < 50% MAHL). The loading of these
pollutants from this IU is considered insignificant at this time.
Average flow, mgd, used in calculations below 0.100
Pollutant Avg. Avg. SIU 5%MAHL 50% Avg. I
SIU lbs/day lbs/day MAHL Influent
mg/1 lbs/day lbs/day
BOD 154 92 31 305
(-)› TSS 167 104 28 280
-L bcki-cu c mos S-cc-twin cS coy° poll uta nts wI 0 Vr
RATIONALE#5b: ret&lyYlt( k"tA-S.
Categorical Parameters with Waived Monitoring:
Monitoring is waived for the following categorical parameters (attach documentation of waiver
justification).
CADMIUM, CHROMIUM, CYANIDE,LEAD,NICKLE, SILVER
Daimler has included FY 2016/17 data and 2017 summary table is
included to support the waived monitoring for this permit duration.
After the HWA is completed this can be reviewed to determine
applicability.
4

Page 22 of
o� W A )i Michael F.Easley
Governor
rWilliam G.Ross,Jr.,Secretary
North Carolina Department of Environment and Natural Resources
O `C Alan W.Klimek,P.E.,Director
Division of Water Quality
December 18, 2002
To: Pretreatment Professionals
From: The Division of Water Quality, Pretreatment Unit
Subject: Pretreatment Requirements
For Mercury Monitoring and Analysis using Method 1631
Pretreatment Program POTWs that received the Division's letter dated August 30, 2002 with the
subject: NPDES Mercury Requirement, Implementation of EPA Method 1631 are reminded of
a few important points.
1. The letter and a list of facilities that received the letter are on the web.
2. The requirement to use Mercury method 1631 (or subsequent low-level mercury
methods approved by EPA in 40 CFR 136) effective September 1, 2003 applies to
Wastewater Treatment Plant EFFLUENT.
3. This applies to all DWQ required Wastewater Treatment Plant EFFLUENT
sampling and analysis. This requirement applies even if mercury is not listed on the
limits page(s) of your NPDES Permit. One of the following conditions may apply
to you - NPDES limited, NPDES monitoring only, Pretreatment Long Term
Monitoring Plan (LIMP), and Pretreatment Short Term Monitoring Plan (STMP)
sampling and analysis. Pretreatment monitoring is a requirement in your NPDES
Permit.
4. Expanding the requirement to do Mercury analysis using method 1631 on samples
collected at other locations in your system such as: your Influent, SIUs, CIUs,
specific types of non-SIUs, un-controllables, trunklines, upstream, downstream,
aeration basin, or any other locations will be decided on a case by case basis
depending on the initial results from using method 1631 on your effluent.
5. Pretreatment Programs require good data and good data analysis by a
knowledgeable experienced pretreatment person in order to develop a valid legally
defensible Headworks Analysis, mass balance, technically based local limits, write
specific pretreatment permit limits and conditions, and to promote pollution
prevention/source reduction. Sometimes more and better data is absolutely
necessary to make wise decisions.
If you are unsure if your facility received the August 30, 2002, Method 1631 letter, please
contact your ORC or consult the list on the Division's web-site. If you have any questions,
please contact your Central Office Pretreatment Staff member.
NC—DENR,DWQ,PRETREATMENT UNIT Telephone: [phone] Fax: [phone] KM&
1617 MAIL SERVICE CENTER, RALEIGH,NC 27699-1617 An Equal Opportunity Affirmative Action Employer
Website: http://h2o.enr.state.nc.us/Pretreat/index.html 50%recycled/10%post-consumer paper
, , 6/13/2(

Page 23 of
Industrial User Pretreatment Permit (IUP)
PART III
Special Conditions
Regulated Categorical Process Flow:
The permittee shall have available flow monitoring equipment at such locations as
necessary to measure the total daily volume of wastewater discharged that is
covered by 40 CFR . This flow monitoring equipment shall also
be capable of measuring flows with a maximum deviation of less than 10% from
true discharge rates throughout the range of expected discharge volumes, however
it is not required that it be continuous recording. At the time of issuance of the
permit, this method consists of
and the frequency shall be and data
shall be collected and reported as required in Part II, 1-4 of this IUP.
Modifications to the flow metering equipment shall be approved by the Control
Authority prior to installation.
NOTE TO PERMIT WRITER: The following are OPTIONAL STREAMLINING
CONDITIONS C11. Monitoring Waiver Parameters
Monitoring by the permittee and the Control Authority has been waived for the
following parameters in accordance with 40 CFR 403.12(e)(2).
Parameter Name 40 CFR Standards
The permittee shall provide the following certification with each report required
by Part II, 2, of this IUP, but in no case less than once every six months.
"Based upon my inquiry of the person or persons directly responsible for
managing compliance with the Pretreatment Standards for 40 CFR ,
I certify that, to the best of my knowledge, there has been no increase in the
level of
in the wastewaters due to the activities at the facility since filing of the [[[last
monitoring report]]] [[[last periodic report under 40 CFR 403.12(e)(1).]]]"
In the event that a waived parameter is found to be present or is expected to be
present based on changes that occur in the permittee's operations, the permittee
shall immediately notify the Control Authority and sample for the parameter
within days of the notification.
12. Equivalent Concentration Limits
16
nnt• ,lank 6/13/21