NC0049867_PreTreatment Audit Inspection Response_20180830

Town of Cleveland
302 East Main Street
P.O. Box 429
Cleveland, NC 27013
[phone]
August 30, 2018
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Mooresville Regional Office
610 East Center Avenue, Suite 310
Mooresville, NC 28115
Subject: Pretreatment Audit Inspection
Town of Cleveland
NOV-2018-PC-0212
Dear Mr. Basinger:
RECEIVEDINCDENRIDWR
SEP 10 2018
WQROS
MOORESVILLE REGIONAL OFFICE
This letter is in response to the Pretreatment Audit Inspection conducted on June 12, 2018 by Mr.
Wes Bell and issued Notice of Violation dated July 3, 2018.
During 2017, the Town of Cleveland had a contract with Statesville Analytical for operation of
the WWTP and Pretreatment program. In late 2017 Statesville Analytical was acquired by
Envirolink. This is the time period that most of the deficiencies occurred. In January of 2018 the
Town began taking a more active role in managing this program by hiring a WWTP operator and
pretreatment coordinator.
To address the items noted in the audit:
1. The STMP that the operator was using for sample collection and laboratory detection
levels was not the same plan that was submitted to PERCS and approved in July
2017. This has been corrected.
2. The previous contractor performed the sampling on the industrial discharge in 2017
and did not analyze all the parameters listed in the permit. This has been analyzed in
2018 according to the permitted parameters in effect at that time.
3. The previous contractor was responsible for submitting the eDMRs for 2017 and did
not include the data for the STMP on them. Those two months of DMR data have
been corrected and resubmitted and the PPA data has been submitted for December
2017. The other two STMP sampling events for 2018 have been submitted on the
eDMR.
4. Low level mercury was analyzed in June and July for the STMP data.

The Town has taken on this responsibility to better manage the program and to control the cost of
operations. In doing this, there has been a learning curve and the previous contractor did not
provide information as to what the status was on the current STMP that had been started in
August of 2017.
The quarterly sample that was missed has been collected so all samples were done within the 12 -
month period that Statesville Analytical started in 2017. All four lift stations were sampled but
the flows from those stations only represent 40,000 gpd of the uncontrollable residential and
commercial flow but the STMP was followed. A revised STMP will be submitted to correct the
detection levels noted that were different than the reported levels on the data that had been
received.
if you need any additional information, please call the Town Hall office at 704-278-4777.
Sinc
IT—
Danny Gabriel
Mayor
W/r
Cc: Wes Bell, DEQ-DWR-MRO