NC0021709_NOV-2021-PC-0613_20211215

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Certified Mail # 7018 1130 0000 1612 8373
Return Receipt Requested
Timothy Church
Town of Jefferson
PO Box 67
Jefferson, NC 28640-0067
NORTH CAROLINA
Environmental Quality
December 15, 2021
SUBJECT: Notice of Violation [NOV-2021-PC-0613] — Pretreatment Compliance Inspection (PCI)
NPDES WW Permit No. NC0021709
Jefferson WWTP
Ashe County
Dear Mr. Church:
Alex Lowe of the Winston-Salem Regional Office conducted a compliance inspection of the Jefferson WWTP
pretreatment program on December 6, 2021. This inspection was conducted to verify that the facility is operating in
compliance with the conditions and limitations specified in NPDES Permit No. NC0021709. A detailed account of
the findings and comments noted during this inspection are provided in the enclosed copy of the inspection report
entitled "Compliance Inspection Report".
Notice of Violation
A file review of the only SIU in the Jefferson WWTP pretreatment program, American Emergency Vehicles, was
conducted, and the industrial user permit (IUP) was confirmed to have expired in July 2021. Mr. Church had
informed Mr. Lowe ahead of the meeting that the permit for this SIU had expired but had not been renewed because
the company was vacating its current address and moving to a new location under a new name, Remount Emergency
Vehicles (see full narrative attached to this inspection report). Lowe confirmed upon inspection that the permit had
expired and that the facility was continuing to operate at a reduced capacity with no permit. This SIU is a categorical
industrial user under 40 CFR 433.17.
Per part IV, section D, subsection five of NPDES permit NC0021709, allowing the permit to lapse while the SIU
continued to operate constitutes failure to maintain legal authority (see 40 CFR 403.3 (v) and 15A NCAC 02H .0906
(b)(6)).
D_E
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem. North Carolina 27105
336.77631800

For this reason, this program is found to be non -compliant, and this letter is being sent as a Notice of Violation. This
requires follow-up to ensure that both AEV and REV are permitted as soon as possible. Please respond in writing to
this office within 30 days of your receipt of this letter regarding your plans or measures to be taken to address this
concern.
If you should have any questions, please do not hesitate to contact Alex Lowe with the Water Quality Regional
Operations Section in the Winston-Salem Regional Office at 336-776-9800 or via email at [e-mail].
Sincerely,
DocuSigned by:
0D2D3CE3F 1 B7456...
Jennifer F. Graznak, Assistant Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Enc: Compliance Report; AEV Narrative
Cc: Michael Montebello, Municipal Permitting Unit
DWR Laserfiche Files
Winston-Salem Regional Office Digital Files
D_E
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 1 Winston-Salem. North Carolina 27105
336.776.98GO

NCNORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
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BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority (POTW) Name: Jefferson WWTP
2. Control Authority Representative(s): Tim Church
3. Title(s): Water Resources Director
4. Last Inspection Date: April 15, 2021 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
ICIS CODING
Main Program Permit Number
MM/DD/YY
J N I C I O 1 0 12 1 1 17 10 19 l J 12 1 06 I 21
7. Current Number Of Significant Industrial Users (SIUs)?
1
8. Number of SIUs With No IUP, or With an Expired IUP?
1
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
either of the Last 2 Semi -Annual Periods? Not Been Published for
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
SNC for
SNC for
Not Pul
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 Al NO
❑ YES i1 NO
Limits: N/A
Reporting: N/A
,lished: N/A
None
❑YES /1NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES
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
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
❑ NO
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)
8/3/2018
' Yes ❑ No
8/7/2018
/1 Yes ❑ No
4/1/2022
Industrial Waste Survey (IWS)
4/25/2019
/1 Yes ❑ No
5/30/2019
/1 Yes ❑ No
5/1/2024
Sewer Use Ordinance (SUO)
11/2/2012
/1 Yes ❑ No
11/7/2012
/1 Yes ❑ No
Enforcement Response Plan (ERP)
6/29/2020
/1 Yes ❑ No
9/23/2020
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
3/16/2018
/1 Yes ❑ No
3/28/2018
/1 Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION
29. User Name
American Emergency Vehicles 2.
3.
30. IUP Number
004
31. Does File Contain Current Permit?
❑ Yes /1 No
❑ Yes ❑ No
❑ Yes ❑ No
32. Permit Expiration Date
07/31/2021
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
to Permit Issue Date?
/1 Yes ❑ No
06/17/2021
❑ Yes ❑ No
❑ Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
11/17/2021
❑ Yes ❑ No
❑ Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. ►Yes •No
b. ■Yes ■ No
a. •Yes ■No
b. ■Yes ■ No
a. •Yes ■No
b. •Yes ■ No
Certification, Does File Contain a Toxic
(TOMP)?
®Yes❑No❑N/A
Cetififed 3/4/2021
❑Yes❑No❑N/A
❑Yes❑No❑N/A
37. For 40 CFR 413 and 433 TTO
Organic Management Plan
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. ►Yes •No
b.❑Yes❑No❑N/A
a. ■Yes •No
b.❑Yes ❑No❑N/A
a. ■Yes •No
b.❑Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
/1 Yes ❑ No
2-17-2021 and
10-26-2021
❑ Yes ❑ No
❑ Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
®Yes❑No❑N/A
4/6/2021
❑Yes❑No❑N/A
❑Yes❑No❑N/A
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
on time?
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑NoEN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑ Yes ❑NoZN/A
En( es❑No❑N/A
❑ Yes ❑No❑N/A
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
i1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
TSS in
September and
December 2020
(caused SNC
for that period)
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑Yes❑NoZN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
44. a. Was the POTW Notified
Monitoring Violations?
b. Did Industry Resample and
c. If applicable, Did POTW
of SIU limit violations in the
by SIU (Within 24 Hours) of All Self-
submit results to POTW Within 30 Days?
a.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
❑Yes❑No®N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
resample within 30 days of becoming awarec.
POTW's sampling of the SIU?
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes 0 No
❑ Yes ❑ No
❑ Yes ❑ No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection?
❑ Yes ❑N°EN/A
❑Yes❑No❑N/A
❑ Yes ❑No❑N/A
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

50. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
FILE REVIEW COMMENTS:
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
a.❑Yes ❑No❑N/A
b.❑Yes❑No❑N/A
❑ Yes /1 No
❑ Yes ❑ No
❑ Yes ❑ No
All is excellent order. No problem locating documents or approvals for program elements.
OVERALL SUMMARY AND COMMENTS:
On Monday, December 6, 2021, Alex Lowe of the Winston-Salem Regional Office conducted a routine Pretreatment
Compliance Inspection at the Town of Jefferson WWTP. Water Resources Director Tim Church was present for the
inspection.
Lowe reviewed the pretreatment program elements and found that all were up to date and properly documented with letters
from the DWR. See table (item number 28 on PCI Report) for dates of latest element approvals and dates of required renewal.
A file review of the only SIU in the program, American Emergency Vehicles, was conducted. This SIU is a categorical
industrial user under 40 CFR 433.17. Mr. Church had informed Mr. Lowe ahead of the meeting that the permit for this SIU
had expired in July of 2021, but had not been renewed because the company was vacating it's current address and moving to
a new location under a new name, Remount Emergency Vehicles (see full narrative as document NC0021709_AEV
Narrative_2021-11-18 on Laserfiche or attached to this inspection report). Lowe confirmed with Mr. Church that the permit
had expired and that the facility was continuing to operate at a reduced capacity with no permit. Mr. Lowe told Mr. Church
that this likely constituted a violation of the POTW's permit, and later confirmed that allowing the permit to lapse while the
SILT continued to operate constitutes failure to maintain legal authority under permit Part IV, Section D, subsection five (per
CFR 403.3 (v) and 15A NCAC 02H .0906 (b)(6)). An NOV has thus been issued in conjunction with this inspection report.
Mr. Church was helpful and forthright in accessing and sharing this information with Mr. Lowe, and stated that he is working
on permitting Remount Emergency Vehicles immediately.
This program is found to be non -compliant, and requires follow-up to ensure that both AEV and REV are permitted as soon as
possible as both are qualified under 40 CFR 433.17. (REV permit application has been received by Mr. Church. Tentative meeting
with Gary Graybeal in mid -December to do a walk-through of new site and identify a reasonable sample point for categorical
sample point (identify Alodine usage area). Will send proposed IUP to Michael Montebello to start permitting process).
NOD: ❑ YES ❑ NO
NOV: ® YES ❑ NO
QNCR: ❑ YES ❑ NO
POTW Rating:
Satisfactory
Marginal
Unsatisfactory X
PCI COMPLETED BY:_Alex Lowe, DWR, WQROS WSRO DATE: December 6, 2021
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

November 18, 2021
American Emergency Vehicles no longer occupies the facility located at 165 American Way just
off Don Walters Road, and in fact no longer exists under this name. This property was sold to a
Christmas tree producer and AEV abandoned the premises in July, 2021. The facility once
known as AEV now operates as REV (Remount Emergency Vehicles) in the building once
occupied by the Gates Rubber Company just off Northwest Drive in Jefferson, NC.
American Emergency Vehicles (AEV) primarily produced new ambulances bodies, while
Remount Emergency Vehicles (REV) focuses more on reconditioning and refurbishing used
ambulances.
AEV still maintains a small presence in the paint building at 165 American Way with less than 20
employees on site, where they continue to prepare a small number of new aluminum
ambulance bodies for priming and painting using Alumiprep. This product contains
hydrofluorosilic acid and its use resulted in AEV being regulated as a 433.17 categorical
discharger as a metal plating operation. In fact, AEV would not qualify as an SIU were it not
using alumiprep.
The compliance manager at AEV has informed me in personal conversation and by email that
AEV is phasing out the use of Alumiprep entirely and the amount on premises will only last
them a few more weeks. The AEV IUP expired July 31, 2021. Given the fact their presence
there is small and they will be totally vacating the facility at any time now, I have chosen not to
renew this IUP. AEV flow is currently at < 300 gpd, compared to the Jefferson WWTP capacity
of 600,000 gpd. The Town has continued to monitor the discharge according to the permit and
AEV has continued their self -monitoring activities with all results being compliant.
Do I need to do anything different in preparation for our upcoming Pretreatment inspection?
AEV did complete an application for permit renewal but given the circumstances I felt that
renewing the permit would be unnecessary. Do I need to take any additional measures?
In regard to the Remount Emergency Vehicles facility (REV), I do have a permit application from
them and I'm gathering information and doing some walk through inspections on their
operations. Presently I view them as nothing more than a vehicle -washing operation. They use
a cleaner known as Alodine for washing the ambulance bodies prior to sanding and painting. To
the best of my knowledge it does not qualify REV as a categorical discharger. I see little or no
evidence this operation should be considered an SIU.
Please share your thoughts and recommendations on this situation as it relates to our
upcoming pretreatment inspection. Thanks.
Tim Church, Water Resources Director
Town of Jefferson