NC0049867_NOD-2019-PC-0124_20190509

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
The Honorable Danny Gabriel, Mayor
Town of Cleveland
Post Office Box 429
Cleveland, North Carolina 27013
Dear Mayor Gabriel:
NORTH CAROLINA
Environmental Quality
9 May 2019
Subject: Notice of Deficiency
Pretreatment Compliance Inspection
Town of Cleveland
NPDES Permit No. NCO049867
Rowan County
Tracking No. NOD-2019-PC-0124
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection of the Town of
Cleveland's approved Industrial Pretreatment Program on May 3, 2019, by Mr. Wes Bell of this Office.
This report is being issued as a Notice of Deficiency (NOD) due to the Town's failure to collect all samples
according to the Industrial User Permit #0001 (Daimler Trucks NA) during the second half of 2018. Specifically,
the Town failed to monitor for aluminum, COD and MBAS during the second semi-annual sampling event in 2018.
It is requested that a written response be submitted to this Office by May 31, 2019, addressing the actions taken to
prevent the recurrence of these violations. In responding, please address your comments to Mr. Bell.
The report should be self-explanatory; however, should you have any questions concerning this report, please do
not hesitate to contact Mr. Bell at [phone] or at [e-mail].
Sincerely,
aDocuSignedd by:
�PiY ��GG
A61696D90CC3437...
for W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure:
Inspection Report
cC: PERCS Unit (Laserfiche)
D Q
� North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
NORTH CAROLINA
Da"MoM a enWmn�bl mwnq 704,663.1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION:
1. Control Authority (POTW) Name: Town of Cleveland
2. Control Authority Representative(s):Barbara Sifford
3. Title(s): Pretreatment Consultant
4. Last Inspection Date: 6/12/18 Inspection Type: ❑ PCI ® Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ® YES ❑ NO
6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES ® NO
Order Type, Number, Parameters: Are Milestone Dates Being Met? ❑ YES ❑ NO ® NA
Main Program Permit Number MM/DD/YY
NCO049867 05/03/19
7. Current Number Of Significant Industrial Users SIUs ?
1
8. Number of SIUs With No IUP, or With an Expired IUP?
0
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year?
0
10. Number of SIUs Not Sampled By POTW in the Last Calendar Year?
0
11. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods?
0
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods?
0
13. Number of SIUs in SNC with Pretreatment Schedule?
0
14. Number of SIUs on Schedules?
0
15. Current Number Of Categorical Industrial Users (CIUs)?
1
16. Number of CIUs in SNC?
0
POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations?
If Yes, What are the Parameters and How are these Problems Being Addressed?
18. Since the Last PCI, has the POTW had any Problems Related to an Industrial
Discharge (Interference, Pass -Through, Blockage, Citizens' Complaints, Increased
Sludge Production, Etc.)?
If Yes, How are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during SNC foi
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC foi
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pu
20. Which Industries are on Compliance Schedules or Orders? For all SIUs on an
Order, Has a Signed Copy of the Order been sent to the Division?
21. Are Any Permits Or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
® YES ❑ NO
See Comments
[—]YES ®NO
Limits: None
Reporting: None
)lished: N/A
N/A
❑ YES ® NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ® YES ❑ NO
26. If NO to 23 - 26, list violations:
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW:
Program Element
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
10/8/18
® Yes ❑ No
1/28/19
® Yes ❑ No
9/1/23
Industrial Waste Survey (IWS)
7/14/16
® Yes ❑ No
10/3/16
® Yes ❑ No
6/1/21
Sewer Use Ordinance (SUO)
1/18/13
® Yes ❑ No
1/23/13
® Yes ❑ No
Enforcement Response Plan (ERP)
7/15/09
® Yes ❑ No
8/13/09
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
3/31/17
® Yes ❑ No
7/13/17
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
29. User Name
1. Daimler Trucks NA, LLC I 2.
3.
30. IUP Number
0001
31. Does File Contain Current Permit?
® Yes ❑ No
❑
Yes
❑
I ❑ Yes ❑ No
32. Permit Expiration Date
6/30/20
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433.17
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
❑ Yes ElNo
ElYes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
I ® Yes ❑ No
❑ Yes ❑ No 11
❑ Yes ❑ No
36. a. Does the File Contain aSlug/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 ONO 11
b. ❑Yes ❑No
37. 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 ?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes ❑No
a. ❑Yes ❑No
a. ❑Yes ❑No
b. All Issues Resolved?
b.❑Yes❑NoEN/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
❑Yes ® fl❑
Yes ❑ No
❑ Yes ❑ No
its Sampling as Required b IUP, includingflow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No 11
❑
Yes ❑ No
❑ Yes ❑ No
41 a. During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Sampling as Required by IUP, including flow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
EYes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
EYes❑No❑N/A
❑Ycs❑No❑N/A
❑Yes❑No❑N/A
file include process/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑NoEN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
production rates and/or flows as Required b IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
OYes❑NoENA
❑Yes❑No❑N/A
❑Yes❑No❑N/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoEN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
All Reporting Non -Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑NoEN/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. Did POTW resample within 30 days of knowledge of SIU limit
c.oyes❑NoEN/A
c.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
violations from the POTW sample event?
45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑
Yes
®
No
❑
Yes
❑
No
❑
Yes
❑
No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑NoEN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
47. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
48. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoEN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
49. a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑NoEN/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
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ®
❑ Yes ❑ No
❑ Yes ❑
Requested Information For You?
!11
ni
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

FILE REVIEW COMMENTS:
17. The POTW's WWTP exceeded the BOD weekly average limit in April 2018 (1 violation), January 2019 (3 violations), February
2019 (2 violations) and March 2019 (1 violation). The BOD monthly average limit was also exceeded in January 2019, February 2019,
and March 2019. A weekly average effluent fecal coliform violation was reported in September 2018.
The POTW staff are currently evaluating WWTP operations and performing additional sampling throughout the collection system to
determine the source of the influent BOD loadings.
35. The POTW performed the inspection at Daimler on 6/12/18.
37. Daimler performs semi-annual TTO sampling and analyses.
39. The POTW contracts R&A Laboratories to perform LTMP and SIU analyses. The POTW failed to collect the semi-annual MBAS,
aluminum, and COD samples (per IUP) during the last half of 2018.
41a. Daimler contracts Pace Analytical Services to perform sample analyses.
SUMMARY AND COMMENTS:
Daimler's contracted lab (Pace Analytical Services) uses a higher detection level (10 ug/L) for arsenic than the required IUP detection
level (5 ug/L). The POTW must ensure Daimler adheres to all required IUP detection levels.
The records reviewed during the inspection were organized and well maintained. The POTW staff must collect additional MBAS,
aluminum, and COD samples during 2019 to make up for the missed samples during the last half of 2018.
Overall, the POTW's Industrial Pretreatment Program was being properly implemented.
NOD: ® YES ❑ NO
NOV: [—]YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ❑ Marginal ❑ Unsatisfactory_ ❑
[�:'.DgOCC3437
ocuSignedd by:
PCI COMPLETED BY:... DATE: 5/9/2019
Wes Bell, Env. Specialist II, Mooresville Regional Office
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3