NC0049867_NOV2018PC0212_20180703

s
Water Resources
Environmental Quality
3 July 2018
CERTIFIED MAIL # 7016 1370 0000 2595 9553
RETURN RECEIPT REQUESTED
The Honorable Danny Gabriel, Mayor
Town of Cleveland
Post Office Box 429
Cleveland, North Carolina 27013
Subject: Notice of Violation
Pretreatment Audit Inspection
Town of Cleveland
NPDES Permit No. NCO048967
Rowan County
Tracking #: NOV-2018-PC-0212
Dear Mayor Gabriel:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
Enclosed is a copy of the Pretreatment Audit Inspection Report for the inspection of the Town of
Cleveland's Industrial Pretreatment Program on June 12, 2018, 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 the subject NPDES Permit. Specifically, the
Town failed to do the following:
1) sample according to the Division approved Short Term Monitoring Plan (STMP);
2) sample all parameters listed in the Significant Industrial User's Permit during the second half of
2017;
3) report all STMP effluent results on the August, October, and December 2017 eDMRs.
Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars
($25,000.00) 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
In order to return to compliance with the requirements of the Pretreatment Program, the Town must
ensure that all future sampling events comply with the Division approved STMP and all parameters are
sampled according to the Significant Industrial User's Permit. In addition, all applicable eDMRs must be
revised and submitted by August 17, 2018.
State of North Carolina I Environmental Quality) Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1610 East Center Avenue, Suite 310 1 Mooresville, North Carolina 28115
704-663-1699

The Honorable Danny Gabriel
Page Two
3 July 2018
It is requested that a written response be submitted to this Office by August 24, 2018, addressing
the Town's actions to prevent the recurrence of these violations. In responding, please address your
comments to attention of Mr. Bell.
Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at
[phone], or via email at [e-mail].
Sincerely,
DocuSigned by:
A14CC681 AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure:
Inspection Report
cc: Monti Hassan, PERCS Unit (via email)

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NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resources
ENVIRONMENTAL QUALITY
Background Information
1. Control Authority (POTW) Name: Town of Cleveland
2. Control Authority Representative(s): Gerald Osborne, Barbara Sifford
3. Title(s): Town Commissioner, Consultant
4. Address of POTW:
Mailing: P.O. Box 429
City: Cleveland Zip Code: 27013
Phone Number [phone] Fax Number [phone] E-Mail clevelandclerk(&clevelandnc.or2
Barbara Sifford/Consultant [phone] le2acy20070)windstream.net
5. Audit Date 06/12/2018
6. Last Inspection Date: 08/16/2018 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ® Yes ❑ No
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ® Yes ❑ No
If Yes, Explain. Weekly Average effluent BOD violation in April 2018.
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
MM/DD/YY
106 112 118
10.
.................................................................
Current Number of Significant. Industrial Users (SIUs)?
I
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?
0
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)
10/04/16
® Yes ❑ No
12/06/16
® Yes ❑ No
10/01/18
Industrial Waste Survey (IWS)
07/14/16
® Yes ❑ No
10/03/16
® Yes ❑ No
06/01/21
Sewer Use Ordinance (SUO)
01/18/13
® Yes ❑ No
01/23/13
® Yes ❑ No
Enforcement Response Plan (ERP)
07/15/09
® Yes ❑ No
08/13/09
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
03/31/17
® Yes ❑ No
07/13/17
® 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 for sampling costs (including STMP sampling costs).
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.
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? Pretreatment Coordinator would review/approve request.
Confidential files would be kept in a locked room/file cabinet.
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 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 loading (BOD/TSS).
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? BOD, TSS, Chromium.
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
IUP in process of being modified to convert BOD and TSS limits to mass -based limits and the chromium limit to
monitor only (based on historical data).
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter 10%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

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 R&A Labs
Conventional Parameters R&A Labs
Organics R&A Labs
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? ® YES ❑ NO
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? 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 ❑NPDES limits change
❑More LTMP data available ❑Resolve over allocation 05 year expiration ❑Other
Explain.
63. In general, what is the most limiting criteria of your HWA? ❑Inhibition ❑ Pass Through ®Sludge Quality
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

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 NC, LLC 2.
3.
67. IUP Number
0001
68. Does File Contain Current Permit?
® Yes ❑ No
❑ Yes ❑
I ❑ Yes ❑ No
69. Permit Expiration Date
6/30/18
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?
I ® 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
I
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 ElNo
ElYes ❑ 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 include process/dilution flows as Required by IUP?
80b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/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 ON/A
❑ Yes ❑ No
❑ 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
becoming aware 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
I
❑
Yes
❑
No
I
❑
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
❑ Yes ❑ No
Information For You?
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

FILE REVIEW COMMENTS:
60a. The POTW failed to collect influent and effluent samples according to the STMP during the January — March 2018 quarter.
No effluent low level mercury sampling was performed (per STMP) during the April — June 2018 quarter. Note: A higher
mercury detection level (0.002 mg/L) was used during the 5/16/18 STMP sampling event.
60b. The POTW's contracted lab (R&A Labs) was using higher detection levels for lead (0.005 mg/L), nickel (0.005 mg/L), and
silver (0.005 mg/L) than the Division approved STMP's detection levels (0.0025 mg/L for all three metals).
60d. STMP effluent results were not reported on the edmrs during STMP sampling events (8/2/17, 10/4/17, December 2017).
72. The POTW inspected Daimler on 11/21/17.
74. Daimler samples for the TTO parameters semi-annually.
76. The POTW samples the SIU semi-annually (per IUP); however, the POTW failed to collect aluminum, molybdenum, selenium,
COD, oil & grease, and MBAS samples during the second half of 2017 sampling event (8/2/17).
78. Daimler contracts Pace Analytical Services for sampling and analyses.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INIC10 10 14 19 18 16 17 I 1061121181
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: Lindsey Speed Title: Sr. Env. Engineer Phone: [phone] Fax: [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 two production shifts and employs approximately 2000 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.
AUDIT SUMMARY AND COMMENTS:
Requirements:
The POTW must sample the influent and effluent in July 2018 to make up for the missed January — March 2018 quarterly STMP
sampling event. An additional low level effluent mercury must also be collected to make up for the missed low level sample
during the 5/16/18 STMP sampling event.
The POTW must either adhere to the lower nickel and lead detection levels in the STMP or submit an updated STMP (with 0.005
mg/L detection levels for both metals) to the Division's PERCS Unit for approval. The POTW should also use a lower silver
detection level (0.001 mg/L) due to the low dissolved metal standard. The lower silver detection level should also be included in
the STMP update/submittal.
The August, October, and December 2017 eDMRs must be revised to include all STMP effluent results and submitted to the
Division by August 17, 2018.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6

Comments:
The records reviewed during the inspection were organized and well maintained.
The Division's PERCS Unit has extended the deadline for the completion/submittal of the HWA to 10/1/18 to allow time for the
additional STMP sampling.
The POTW must ensure of the following: comply with all requirements in the Division approved STMP; sample all parameters
according to the SIU's IUP; and report all STMP effluent results on the eDMR.
NOD: ❑ Yes ® No
NOV: ® Yes ❑ No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ❑ Marginal ® Unsatisfactory ❑
a—,96D90CC3437
cuSignedd by:
Audit COMPLETED BY• ... DATE: 7/2/2018
Wes Bell, WQROS, Mooresville Regional Office
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7