NC0021709_NOV and Intent to Assess_20200313

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
Certified Mail # 70181130 00001612 7314
Return Receipt Requested
March 13, 2020
Mr. Tim Church, Water Resources Director
PO Box 67
Jefferson, NC 28640
SUBJECT: Pretreatment Compliance Inspection Report
Notice of Violation with Intent to Enforce
NOV Tracking # NOV-2020-PC-0143
NPDES# NCO021709
Town of Jefferson, Ashe County
Dear Mr. Church:
On March 3, 2020, Paul DiMatteo of the Division of Water Resources, Winston-Salem Regional
Office conducted a Pretreatment Compliance Inspection at the above referenced wastewater
treatment system. The purpose of this inspection was to determine the effectiveness of the
Town's pretreatment program, which included: reviewing the files, POTW plant performance,
sampling and compliance judgement program, and adherence to the Enforcement Response Plan.
Background
The Town operates one 0.600 MGD facility and has one significant industrial user, which is
categorically regulated under 40 CFR part 433.
POTW Interview
There have been no NPDES permit limit violations in 2019 and Mr. Powell indicated that he has
had no issues implementing the pretreatment program.
Please refer to the attached report for additional file review comments and requirements.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on November 2, 2017 and approved on
December 4, 2017. The next HWA is due on April 1, 2022.
D � North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office [ 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
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The City's last Industrial Waste Survey (IWS) was submitted on April 25, 2019 and was
approved on May 30, 2019. The next IWS is due May 1, 2024.
The last Short -Term Monitoring Plan (STMP) was submitted on March 9, 2018 and approved on
March 28, 2018.
The Sewer Use Ordinance (SUO) was approved on November 7, 2012.
The ERP was approved on April 7, 2003.
STMP Review
The STMP only requires monitoring the year before NPDES renewal and therefore monitoring is
not currently being conducted.
Industrial User Permit (IUP) File Review
American Emergency Vehicles' permit (#004) expires on July 31, 2021. Chain of custody forms
and lab reporting were in good order. The inspector identified issues with compliance judgement
that are discussed in the attached report.
Notice of Violation
During the inspection, the Inspector identified issues with failure to properly implement the
POTW's approved Enforcement Response Plan by neglecting to properly identify or action
violations within the time frame and actions specified in that plan. Issues with implementing the
ERP were also identified during the previous inspection, for which a Notice of Violation was
also issued.
Required Actions
This Notice of Violation / Notice of Intent to Enforce (NOV/NOI) is being issued for the noted
violation. 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.
This office requests that you respond to this Notice, in writing, within 30 business days of
its receipt. In your response, you should address the causes of non-compliance, remedial
actions, and all other actions taken to prevent the recurrence of similar situations. The response
to this correspondence will be considered in this process.

If you have any questions, please contact Paul DiMatteo at [phone] or
Paul.Dimatteo(d),ncdenr.gov; or our office at [phone].
Sincerely,
D'ocu Siiggned by:
Li7-
145B49E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
Enclosures — Inspection Report
cc: DWR Laserfiche Files

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Waterkesaurces
ENVIRONMENTAL OVAL I TY
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)l
1. Control Authority (POTW) Name: Jefferson
2. Control Authority Representative(s): Tim Church
3. Title(s): WWTP ORC/Pretreatment Coordinator
4. Last Inspection Date: 3/3/2020 Inspection Type (Check One): ❑ 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:
ICIS CODING
Main Program Permit Number
NIC10 10 12111710191
MM/DD/YY
103 1 03 1 20 1
Are Milestone Dates Being Met? ❑ YES ❑ NO
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?
1
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
11
16. Number of CIUs in SNC? 11
1
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 for
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not PuI
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
❑ YES ® NO
Limits: AEV
Reporting: None
Ilished: AEV
None
[:]YES [—]No
LTMP/STMP FILE REVIEW: Monitoring onlv reauired the vear before NPDES permit renewal so not currently being conducted.
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 Division Inspector, please verify
yourself!
26.
27.
If NO to 23 - 26, list violations
Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP?
If yes, which ones? Eliminated: Added:
NC DWR Pretreatment Compliance Inspection (PCI) Form
Updated December 2016 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW- Please review POTW files, verify POTW has copy of Program Element
in their files, complete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Program Info:
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
11/2/2017
® Yes ❑ No
12/4/2017
® Yes ❑ No
4/1/2022
Industrial Waste Survey IWS
4/25/2019
® Yes ❑ No
5/30/2019
® Yes ❑ No
5/1/2024
Sewer Use Ordinance (SUO)
8/26/2011
® Yes ❑ No
11/7/2012
® Yes ❑ No
Enforcement Response Plan (ERP)
1 2/27/2003
® Yes ❑ No
4/7/2003
® Yes ❑ No
Short Term Monitoring Plan (STMP)
3/9/2018
® Yes ❑ No
3/28/2018
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. AEV 2.
3.
30. IUP Number
004
31. Does File Contain Current Permit?
® Yes ❑ No
❑ Yes ❑
I❑ Yes ❑ No
32. Permit Expiration Date
7/31/2021
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 ❑ No
❑ Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
® Yes ❑ No
❑ Yes ❑ No 11
❑ Yes ❑ No
36. a. Does the File Contain a 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
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?
®Yes ❑No
ROYesONoIR
a. ❑Yes ❑No
a. ❑Yes ❑No
b. All Issues Resolved?
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
its Sampling as Required by IUP, including flow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑
No
41. 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
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No[D
❑Yes❑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❑No®N/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
❑ Yes ® No
ElYes ❑ No
❑ Yes ❑ No
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
All Re porting_Non-Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑YessNo❑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 within 30 days of becoming aware
c.®Yes❑No❑N/A
of SIU limit violations in the POTW's sampling of the SIU?
c.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
®
Yes
❑
No J1
❑
Yes
❑
No
I
❑
Yes
❑
No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes®No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
50. a. Does the 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[9
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ® No
❑ Yes ❑ No
ElYes ❑ No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

FILE REVIEW COMMENTS:
- The Industry had one TRC violation for lead in October. They conducted additional sampling in December which helped
them avoid SNC. However, the Industry also analyzed additional zinc samples in December. Results showed they had a
TRC violation for the December monthly average. Since they only had 2 reported months for the semi-annual period, they
are in SNC for Zinc for that period.
- The Industry also started adding pH adjustment to its wastewater. We discussed that the POTW and Industry should
identify a point for the industry to monitor pH for adjustment that would not be considered the "effluent" for compliance
purposes.
- POTW did not identify or action the above identified violations within the time frame and action requirements specified in
its approved Enforcement Response Plan. POTW is to send the appropriate notices for the violations noted above.
- We discussed having the Industry sample earlier in the semi-annual period, so that there is more time to address violations
before they become SNC.
- POTW should date -stamp correspondence received from the Industry.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
1. Industry Inspected:
2. Industry Address:
3. Type of Industry/Product:
4. Industry Contact: Title:_
Phone: Fax:
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:
None
OVERALL SUMMARY AND COMMENTS:
Comments:
Requirements:
Recommendations:
NOD: ❑ YES ❑ NO
NOV: ® YES ❑ NO
QNCR: ❑ YES ❑ NO
POTW Rating:
Satisfactory Marginal Unsatisfactory
[�F=7UE5BBUN
DOCUSigned by:
PCI COMPLETED BY:Z." &M°7`O' WSRO DATE: 3/13/2020
..
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3