NC0049867_NOV-2019-LV-0192 Response_20190402

Town of Cleveland
302 East Main Street
P.O. Box 429
Cleveland, NC 27013
[phone]
April 2, 2019
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
NCDEQ-Mooresville Regional Office
610 East Center Ave., Suite 301
Mooresville, NC 28115
SUBJECT: Response to NOV-2019-LV-0192
Dear Mr. Basinger:
0 9 r.ON
This letter is in response to the above Notice of Violation received March 25, 2019.
Around the week of Christmas, the wastewater treatment plant was out of state limits for
BOD in water discharged into Third Creek. Our investigation led us to suspect illegal
dumping into the sewer system. On December 19, January 3, January 23 and January 31,
the total suspended solids (TSS) jumped up from the normal 500 mg/1 to 2480, 2900 and
5240 mg/l respectively.
The following actions were taken during this time period:
12-17-18 received 12/19 sample results and effluent BODs elevated at 30.1.ORC
added 4 bags of dehydrated bugs just in case.
1-3-19 sample results from 12-27 received and effluent BODs were 33.3. R & A
Labs called ORC to discuss.
1-10-19 Lab called ORC to report that 1/3/19 samples are even higher at >40.7.
ORC added 6 bags of bugs. Also called Fred Summers with NC Rural Water
Association to see if he could get us a microscope. Commissioner Gerald Osborne
was also called and he immediately notified Daimler Trucks of increase.
1-11-19 Mr. Summers (NCRWA) brought a microscope from Cooleemee W WTP
and found very little life and many empty shells. ORC added 4 more bags of bugs.
Lab ran a COD from 1-9-19 samples and called to say they were very high (>700).
Final results were 156.
1-15-19 ORC called Roberto Scheller in Mooresville Regional Office to report.
1-17-19 ORC took ditch sludge samples to Cooleemee to use their microscope
and found lots of life. Lab called to report CODS for 1/16/19 samples were way
down.
1-24-19 Lab called to report 1-23-19 samples were again way down. Got BOD
results from 1/16/19 of 83.0.

1-29-19 ORC emailed Roberto Scheller (see attached email) all updated info since
day 1. Started to notice a color change in clarifiers and contact chamber, dark and
murky. Effluent water not as clear as usual. This is the first time since having high
BODs that there is a noticeable different look to the effluent.
1-31-19 Got BOD results from 1-23-19 of 55.5. Lab called to report that samples
from 1/30/19 CODS were up again. Final 1-30-19 results gotten on 2-6-19 of 77.8
BODs.
Wastewater Commissioner Gerald Osborne notified Lindsay Nichols, Daimler
Environmental Engineer, about the BOD increase. A memo was issued to Ms. Nichols on
January 18, 2019 describing the BOD increase (see attached.)
On February 13, 2019, Ms. Barbara Sifford, Town Pretreatment Coordinator, visited
Daimler and reviewed all activities during the BOD upset period (see attached report
from Ms. Sifford.)
During February, the BOD continued to be irregular with these results: Feb. 6 — 62, Feb.
13 —17.8, Feb. 20 —18.8, February 27 — 38.5. The following actions were taken during
February:
2-5-19 Roberto Scheller visited the W WTP to look at sludge and to help with advice.
2-6-19 Lab called to discuss results from 1/30/19. Decided to pull a grab sample
from each clarifier to send in with that days' routine samples.
2-7-19 Lab called to report that both clarifier CODs were low but effluent was high.
Possible de-chlor contamination (?). Later that day, got a call from contractors from
the old school that they found 4 jugs of concentrated cleaner had been dumped
down the drain.
2-12-19 Increased chlorine feed to contact chamber 2 pounds and decreased sulfur
dioxide 5 pounds per day. Noticed a clearing of the contact chamber. Emailed
Roberto Scheller updated info. (see attached email.) He called back later to discuss
what kinds of cleaners were found from the empty jugs.
2-13-19 Lab called to report a BOD of 62.1 from 2/6/19 samples.
2-14-19 Noticing that clarifiers are starting to look much better. Lab called to report
an 80 COD from yesterday's samples. We thought it would be much better
considering the large decrease of de-chlor.
The Town Maintenance Director visited the old Cleveland Elementary School on
February 7, 2019 and found the following. Three types of lightning blend cleaners and a
Franklin brand cleaner had all been dumped into a mop sink. The lightning blend had the
following numbers: F379022, F455522 and F453022. The Franklin brand was Q-128, a
germicidal detergent and deodorizer. Each of these were 1-gallon jugs. A meeting was
held on February 26 with the school maintenance supervisor to review the findings found
on February r. He informed us that these cleaning chemicals were old and reviewed all
current school chemicals.
On Feb. 20, 2019, a continued action plan was defined and was implemented into March.
See attached plan. March continued to be irregular with following BOD result: 3/3 —
38.5, 3/12 — 28.4, 3/13 — 64.8, 3/20 —17.7.

As you can see, the Town has diligently been searching the cause of the high BOD
violations and taken numerous steps to try to alleviate the impact to our system. We even
sent out a memo to the residents and businesses to be alert and report any activity they
see around any sewer manholes. If there is any technical assistance that you offer that
can help to stabilize the wastewater treatment system, we would greatly appreciate it.
Sincer
f
Danny Gabriel
Mayor
cc: Commissioner Gerald Osborne
attachments
SENT VIA EMAIL — core,y.basingerkncdenr.gov
SENT VIA EMAIL — roberto.schellerkncdenr.gov
HARD COPY SENT FIRST CLASS MAIL

TOWN OF CLEVELAND
PO Box 429
Cleveland, NC 27013
704-278-4777
Fax:[phone]
January 18, 2019
Daimler Trucks
Attention: Lindsay Nichols
PO Box 399
Cleveland, NC 27013
Mrs. Nichols:
The WTP effluent BOD has been well within limits (attached chart). The sample taken
on 12/19/18 produced a result of 30 mg/L. The following week, 12/26/18 sample result
was 33 mg/L. The 1/3/19 sample was 40+ mg/L. At this point samples of bacteria
activity were evaluated and found to be quite inactive. This indicates a bacteria kill has
occurred. New bacteria seed was added 1-10-19 and 1-11-19. The 1-9-19 sample
activity was 152 mg/L. On 1-17-19 a bacteria sample was evaluated and found to be very
active. The COD value was 700+ the week of 1 /3/19 and the COD value for week
1/10/19 was 150. Hopefully the BOD sample for 1-16-19 will be back within limits.
Reviewing the Daimler December report, the December 22 Pipe 1 flow rate was reported
to be 0.174 MGD. Pipe 1 flow rate has averaged 0.03 MGD with max flow rate no
higher than 0.05 MGD (attached chart and data).
Please provided reason for such an extreme rate. The molybdenum level has been less
than 0.005 mg/L with the December value of 5.4 mg/L. Please provide the reason for this
high level.
A timely response would be appreciated.
Gerald Osborne
Sewer Commissioner

To: Town of Cleveland Site visit to Daimler
From: Barbara Sifford — Pretreatment Coordinator
Subject: Compliance Investigation for January 2019 BOD Exceedances
On February 13,1 met with Lindsey Nichols at Daimler Trucks about the shutdown procedures
conducted over Christmas holiday break. They emptied all treatment tanks by processing the
water through the treatment system. Then all sludges were removed and disposed of off- site.
The water usage during that week as indicated by the flow meter would be from leaking
fixtures and not any production usage. This occurred during December 21 and January 2.
In looking at WWTP data for the period of January, the flows were elevated due to the extreme
rainfall that occurred. We evaluated the pump station records to isolate a particular section of
the collection system that might have inflow and infiltration. Manholes in the area were to be
checked.
Also occurring during December and January was the preparation of the Cleveland Elementary
school for demolition. The county had hired a contractor to do this work and several containers
of biocide and disinfectant were noted as being poured down the drain for disposal. This is
probably the cause of the biological inactivity of the WWTP. At the time no inventory was
noted as exactly how much was disposed of in this manner.
The higher flows and lower food supply along with the biocides probably caused the killing off
of the biomass of the WWTP.

MEMORANDUM
DATE: February 20, 2019
TO: Town Board, Paul Land, Tim Taylor
FROM: Gerald Osborne, Water/Sewer Commissioner
SUBJECT: Action Plan for WWTP Upset
1. Issue an alert letter to citizens and businesses about upset and suspicion
2. Review monthly FOG Reports for grease trap pump outs.
3. Evaluate manholes for clean-up towel dumpings
4. Review Mueller water/sewer system
5. Mark certain manholes for observation and requested the Police
Department to patrol these areas.
6. Consider manhole pans for certain locations
7. Meet with school maintenance to review cleaning chemicals
8. Visit neighbors at Fiber Acres and Hwy 70 lift station area.
9. Install pH monitor in influent to WWTP.

Date: 01/29/2019 [08:42:06 AM CST]
From: [e-mail]
To: [e-mail]
Subject: Town of Cleveland high BODs
Hello. The following is a breakdown and update to the high BODs for the last month for the Town of
Cleveland.
On Dec 19th we received elevated BOD results of 30.1. This is unusual for our plant so I threw in a
few bags of bugs just in case. The following week (Dec 12th) the results were again 33.3. Hoped the
problem had stabilized so made no adjustments.
The following week (Jan 10th) I was contacted by the lab to inform me that the BODs are continuing
to rise with a result of >40.7. with that we decided to start running CODS for future samples so we
would know sooner if this problem is getting better or worse.
Added several more bags of bugs to both our basins.
On Jan 11th Fred Summers from NC Rural Waier borrowed a microscope from Cooleemee to check my sludge
and we found extreme low levels of life. At this point we are assuming the possibility of a an upset
from our SIU. Added a few more bags of bugs and continued to investigate.
The same day the lab called me to report that the Jan 9th samples COD were extremely high at over
700. At this time knew that we would be in violation so called to report on the 15th. Final BOD
results from week was 156.
On Jan 17th I took some sludge samples to Cooleemmee to use their microscope and found a huge
increase of life. The lab called the same day to say that the COos from Jan 16th samples were way
down. Final BOO for that week were down but still out -of -spec at 83.0. Seems to have turned the
corner and will hopefully continue to improve.
At this time I haven't received anymore results but I will update the progress as soon as they're in.
Thank you,
Paul Land ORC Town of Cleveland

Date: 02/12/2019 [10:29:02 AM CST]
From: [e-mail]
To: [e-mail]
Subject: Town of Cleveland high BODs update
Hello, Roberto. Wanted to give you a update on our high BOD issue.
I ended the last email with results from Jan 16th of 83.0. The following week Jan 23rd we got results
of 55.5 and thought for sure the next sample will finally be in -spec but instead it went back up to
77.8.
I don't have anymore results since then except for CODS that were run on Feb 7th that were even
higher so we know we're still headed up again. Did a microscope check yesterday and our bug
population seems to still be in good shape.
Last Wednesday Feb 6th a town board member was doing the daily checks on the old school that is
scheduled for demolition and found that someone had poured 4 large jugs of concentrated cleaners down
the drain between Tuesday morning and Wednesday. We have the jugs and plan to investigate further and
ask what has been their disposal procedures since the school closed on Dec of last year.
Thank you for your time,
Paul Land

Date: 02/26/2019 [09:45:27 AM CST] 4iy2�
From: [e-mail]
To: [e-mail]
Subject: Town of Cleveland high SOD update
Hello, Roberto. Hopefully this will be the last email about our high BODs.
The results for Feb 6th were still high at 62.1 but the next ones on Feb 13th were finally in -spec at
17.8. Hopefully the upset is over and has cycled thru and our numbers will continue to drop.
i want to thank you for your help and suggestions. Been a huge unwanted learning experience to say
the least.
Hope you have a great week.
Thanks again,
Paul Land