NC0021709_Annual Report_20180604

Town of jeffezzon Water IZe o-U rcdets-
1233 Highway 16 South P.O. Box 67 Jefferson, NC 28640 336.246.2165
"Pr New Rives'B "
Cathy Howell,Town Manager Tim Church, Director
June 4, 2018
NC Division of Environmental Quality
PERCS Unit
1617 Mail Service Center RECEIVED!®ENS®��
Raleigh, NC 27699-1617 JUN'® � 201
ATTN: Ms. Vivien Zhong
Water Resources
SUBJECT: Revision of Town of Jefferson Pretreatment Report Permitting
Dear Ms. Zhong:
A review of the most recent pretreatment semiannual activity for the Town of Jefferson
revealed that a Notice of Non-Compliance sent to our only Significant Industrial User,
American Emergency Vehicles for an excessive BOD value should have actually been
issued as a Notice of Violation /Significant Non-Compliance.
To correct this situation, I have issued the NOV/SNC to American Emergency Vehicles
and placed a public notice in our local newspaper, Ashe Post & Times. In addition I
have revised the narrative portion of our Pretreatment Annual Report to reflect this
NOV/SNC, corrected the PPS form and the significant non-compliance report. I have
included 2 copies of each of these corrected documents in this correspondence and
assume that you will furnish one set of those to the Winston-Salem Regional Office.
Subsequent samples collected in April and May 2018 at American Emergency Vehicles
by the Town as well as the SIU have produced results well within the IUP limits for BOD.
I feel this SNC likely resulted from an anomaly with our laboratory, however I have also
cautioned AEV to monitor its disposal of paint thinners and other VOCs due to the fact
that they are used in close proximity to the categorical sampling point. The SIU has also
been encouraged to collect samples early within the compliance period in order to
allow additional compliance sampling.
I apologize for any inconvenience this oversight may have caused.
Respectfully,
.ivvv C.44-A.41/4.44.,
Tim Church, Water Resources Director
Town of Jefferson
[e-mail]

Narrative for the Town of Jefferson Water Resources Pretreatment Program
Annual Report 2017
The Town of Jefferson Pretreatment Program serves American Emergency Vehicles as
its only Significant Industrial User. This facility is regulated as a 40 CFR 433.17
Categorical metal finishing facility as the result of a process that uses a fluoridated
etching solution to prepare raw aluminum ambulance bodies for primer coating and
painting.
American Emergency Vehicles has a long history of cooperation and compliance with
the Town of Jefferson Pretreatment Program. In 2017 AEV completed both of its
required semiannual sampling events. The Town of Jefferson also completed two
semiannual events. All sampling conducted for the first semiannual period of 2017
produced compliant results.
A sample collected by the Town of Jefferson on November 7, 2017 yielded a BOD of 720
mg/I. The permitted BOD limit for AEV is 400 mg/I. As a result, the SIU was found to be
in Significant Non-Compliance for BOD for the second semiannual period of 2017.
A Notice of Violation (SNC) was sent to Mr. Gary Graybeal, Compliance Manager. As
part of the NOV, Mr. Graybeal was requested to take two specific measures to address
this matter. Sample collection early in the compliance period is suggested to prepare
for any anomalies by allowing time for additional compliance sampling. Also, efforts
should be made to identify and eliminate sources that could contaminate the
Categorical wastestream
A Public Notice of this SNC was also placed in the Ashe Post & Times, the major
newspaper circulated in Ashe County. The newspaper also featured a story in the same
edition that outlined the details of this event.
The HWA calculations for Jefferson have been completed by Michael Whittenburg of
McGill Associates, PA. The Town of Jefferson WWTP received NPDES permit renewal
effective February 1, 2018 and will be required to use the hardness calculator for new
stream standards, with a revised HWA due on August 1, 2018. An updated STMP based
on the renewed permit has been submitted to PERCS and accepted.
American Emergency Vehicles was issued a permit renewal effective August 1, 2017 and
expiring on July 1, 2021. A statement of permit adequacy from PERCS and a letter of
transmittal to the SIU is on file.

Chapter 9, PAR Guidance
Pretreatment Performance Summary (PPS)
1. Pretreatment Town Name; T
Own of`.J f cern 57t.
2/709 fo Tcolumn
2. "Primary" NPDES Number NC00 f�=office
USC only
or Non Discharge Permit#if applicable=> WENDB
coda
3. PAR begin Date, please enter 01/01/yy or 07/01/yy 3.=> I/I D 17 PSSD
4. PAR end Date, please enter 06/30/yy or 12/31/yy 4.=> 12/31/17 B7 PS®
5. Total number of SIUs,includes CIUs 5._> I SNS
6. Number of CIUs 6.=> l chis
7. Enter the Higher Number,either (7a) or (7b) here=> I NOIN
7a. Number of Sills not sampled by POTW 7a.=> ()
7b. Number of SIUs not inspected by POTW 7b.=>
8. Number of SIUs with no IUP, or with an expired IUP 8.=> NOCM
9. Total Number of SIUs in SNC due to either IU Reporting violations or
IUP Limit violations. To avoid double counting some SIUs
Enter (9a+9b) -9c here=> I PSNC
Enter the Number of SIUs in SNC for:
9a. IU Reporting violations 9a.=>J) MSNC
9b. IUP Limit violations 9b.=> 1 SNPS
9c. Both IU Reporting&i.imit violations 9c.
10. Number of SIUs in SNC due to IU Reporting violations
that were not sampled or inspected by POTW 10.=> 0 sNIN
11. Number of SIUs in SNC due to violation of 11.=> () SSNC
Compliance Schedule due dates
12. Number NOVs,NNCs,AOs,or similar assesed to SIUs 12.=> I FENF
13. Number Civil or Criminal Penalties assessed to SIUs 13.=>21._ JUDI
14. Number of SIUs included in public notice 14.=> I svPu
15. Number of SIUs from which penalties collected 15.=> IUPN
16. Total Amount of Civil Penalties Collected ' 16.=> $ b
17. Total Number of Sills on a compliance schedule 17.=> () sots
[Foot Notes: AO Administrative order NOV Notice of Violation
CIU Categorical Industrial User PAR Pretreatment Annual Report
CO Consent Order POTW Public Operated Treatment Works
IUP Industrial User Prareatmeat Permit SW Significant Industrial User
NNC Notice of Non-Compliance SNC Significant Non-Compliance,formerly RNC
Chapter name: PAR Guidance
File name: PAR PPS.alr Comprehensive Guide, Chapter 9, Section B, Page 5
Revision date:August 1,1994 Blank PPS Form,Copy and use in your PAR

•
Pretreatment Annual Report (PAR) PAR covers this calendar year=> 2oi
Significant Non-Compliance Report (SNCR) Control Authority=Program=Town Name => Se ersor
WWTP= Wastewater Treatment Plant, use separate form for each WWTP. WWTP Name => Topers, VY W [ P
SIU = Significant Industrial User NPDES# => mon 217Oa
SNC = Significant Non-Compliance
A SNCR Form must be submitted with every PAR, please write "None " if you had No SIUs in SNC during calendar year
SNC? (Yes/No)
IUP Pipe Industry Name Parameter for each 6-month period.
# # or"Reporting" Jan.-June July-Dec.
oo� 01 Aypprjcan Eme,ey Velities Bob No Yes
Attach a copy of the Division's "SIUs in SNC Historical Report" for your POTW's SIUs behind this page .
Is the database correct ? Notify the Division of any errors ! Database indicates SNC history for previous years.
EVERY SNC MUST be explained in the Narrative, How was, is, or will it be resolved?
REPEAT SNCs are serious matters that MUST be explained in the Narrative.
Form name: PAR,SNCR,2001 •
Date Revised 1/4/2001

TOWEll, of jeffersom Wator IZe o rce (
1233 Highway 16 South P.O. Box 67 �p�Jpefyf/e�r�soyn,, NC 28640 336.246.2165
6PP l� Naw obi e - 9)
Cathy Howell,Town Manager �/Y Tim Church, Director
May 14, 2018
American Emergency Vehicles
165 American Way
Jefferson, NC 28640
ATTN: Mr. Gary Graybeal, Compliance Manager ,
SUBJECT: Notice of Violation
Significant Non Compliance: BOD July-December, 2017
Gary,
The notice of non-compliance issued to AEV in February, 2018 for BOD violations
during the second semiannual period of 2017 has been reviewed by North Carolina
Division of Environmental Quality. Their findings indicate the levels of BOD in a
sample collected at AEV on November 7, 2017 result in Significant Non Compliance for
the second semiannual period of 2017 for American Emergency Vehicles.
The Town of Jefferson has issued a Public Notice of this violation in the local newspaper.
AEV is requested to submit any BOD data collected in its discharge during the first
semiannual period of 2018 to the Town of Jefferson immediately. This information will
be compiled with sample data collected in May by the Town of Jefferson to determine
present compliance status. The Town also encourages efforts to locate and eliminate
sources of BOD that could be entering the categorical sample site listed in Industrial
Pretreatment Permit#004.
As you are aware, sampling early in the semiannual period and encouraging commercial
laboratories to report analytical results to you as soon as available provides an opportunity
to collect additional re-samples that can provide satisfactory compliance judgment in the
event of analytical data that may be influenced by anomalies.
Thank you for your assistance to the Town of Jefferson as we continue to protect the
waters of the New River Basin. If you have questions regarding this matter, please call
me at [phone].
Sincerely,
7-:"ivy..61.tAAci----
Tim Church, Water Resources Director
Town of Jefferson
[e-mail]

This Public Notice and the related news article
appeared in the May 16, 2018 editions of the TOWN OF JEFFERSON, ,
'WATER RESOURCES
Ashe Post & Thnes. , PUBLIC NOTICE--,
The wastewaterdischarge of
American',Emergency ,Vehicles":
;.; to the Town of Jefferson Sank
The newspaper will provide a Publisher's tary' Sewer Collectibm"Systerit
',has'been determined to be,in'
Affidavit to the Town. Significant Non-comPliance fbr
BOD that exceeded-the limits
set forth,'within Industrial,User
:Permit# 004 held by AEV.The',
, iolationacctirrodi
collected by theTownof Jeffe(1,,
son'during ithe seeend serniani-
'nual,moniforing period of 2q17.
vigiation,Caused no,hami '
f6 the-TewirN coffectio,n sysiem!
and caused-no excessive leVels
cifliOD,ta be fóundinthoffluv
e
env of the, ToWn of,jeff,erson-
' Wastewalorl TreatthentFiaflt
Efforts are-underway r to,deter-1
'mine the source Or this vIoIa
tion. ;
,Tim Church
Water Resources Dire4tOr
' Town of Jefferson ;-
' May 9.-20113.:'
AEV--fOland to,b beinsignificant rioti-Cornpliance,
---,ofjefferson wastewater dischargepolicy
BY LEE SANDEILLIN Water monitoring period of 2,017.1 they have issues with that paparemeter.
I '
, ke.sonilidaies.ao ' .130D is the amount of diss oh•edniygen 'It's not that common(to have sampling
n'deded by aerabic biological Organisms to • 'anomalieS),but sometimes se have
, - -
''JEFFERSON--,-,American Emergency break down orgmiEmatrial present in a, - be'high-and requite
,
Vehicles was found tobe,in significant given water sample. r " ' additional sampling to get theft.numbers
non-compliance,of town of Jefferson _ Church said that hebelieves AEV s high back intocomplianceand usually that
waste ater dischar6,0110,acLordmg to 1.106 numbers to be an,",'„anomaly,"tAit,, solves theproblern."
F .Jefferson Water Itesaineei,Direetof Tim thaf additional testing will be,ebUduct4 'Church'also stated that there was no
Qhurch. 'From time to time,an industrvWill damage to the town's,collection system
,
AEV had highlevels of biOchendeal -iample'andcome'up with,aomehigh num- and that there\were no excessive leyela
oxygen demanding pollutants mitts water berS'andAE'Vhas some high numbers, DOD to be found in the,effluent of the
-I ,
sample from Jefferson's seedndsernian-'. -Church said: 1 have no reason to believe town'slvastewater treatment plant'',

Narrative for the Town of Jefferson Water Resources Pretreatment Program
Annual Report 2017
The Town of Jefferson Pretreatment Program serves American Emergency Vehicles as
its only Significant Industrial User. This facility is regulated as a 40 CFR 433.17
Categorical metal finishing facility as the result of a process that uses a fluoridated
etching solution to prepare raw aluminum ambulance bodies for primer coating and
painting.
American Emergency Vehicles has a long history of cooperation and compliance with
the Town of Jefferson Pretreatment Program. In 2017 AEV completed both of its
required semiannual sampling events. The Town of Jefferson also completed two
semiannual events. All sampling conducted for the first semiannual period of 2017
produced compliant results.
A sample collected by the Town of Jefferson on November 7, 2017 yielded a BOD of 720
mg/I. The permitted BOD limit for AEV is 400 mg/I. As a result, the SIU was found to be
in Significant Non-Compliance for BOD for the second semiannual period of 2017.
A Notice of Violation (SNC) was sent to Mr. Gary Graybeal, Compliance Manager. As
part of the NOV, Mr. Graybeal was requested to take two specific measures to address
this matter. Sample collection early in the compliance period is suggested to prepare
for any anomalies by allowing time for additional compliance sampling. Also, efforts
should be made to identify and eliminate sources that could contaminate the
Categorical wastestream
A Public Notice of this SNC was also placed in the Ashe Post & Times, the major
newspaper circulated in Ashe County. The newspaper also featured a story in the same
edition that outlined the details of this event.
The HWA calculations for Jefferson have been completed by Michael Whittenburg of
McGill Associates, PA. The Town of Jefferson WWTP received NPDES permit renewal
effective February 1, 2018 and will be required to use the hardness calculator for new
stream standards, with a revised HWA due on August 1, 2018. An updated STMP based
on the renewed permit has been submitted to PERCS and accepted.
American Emergency Vehicles was issued a permit renewal effective August 1, 2017 and
expiring on July 1, 2021. A statement of permit adequacy from PERCS and a letter of
N transmittal to the SIU is on file. .

Chapter 9, PAR Guidance
Pretreatment Performance Summary (PPS)
1. Pretreatment Town Name: 7Jfl of ffets
This Column
2. "Primary" NPDES Number NCOO i?; 9 for office
use only
or Non Discharge Permit#if applicable=> WEPA
codes
3. PAR begin Date,please enter 01/01/yy or 07/01/yy 3.=> J/( /17 PSSD
4. PAR end Date, please enter 06/30/yy or 12131/yy 4.=> 12/31/17 PSED
5. Total number of SIUs, includes CIUs 5._> 1 slur
6. Number of CIUs 6.=> Crus
7. Enter the Higher Number, either (7a) or(7b) here => NOIN
7a. Number of SIUs not sampled by POTW 7a.=> ()
7b. Number of STDs not inspected by POTW 7b.=> d
8. Number of SIUs with no TUP, or with an expired IUP 8.=> 0 NOCM
9. Total Number of STDs in SNC due to either IU Reporting violations or
IUP Limit violations. To avoid double counting some SIUs
Enter (9a+9b) - 9c here=> ! PSNC
Enter the Number of SIUs in SNC for :
9a. IU Reporting violations 9a. 0 MSNC
9b. IUP Limit violations 9b.=> SLAPS
9c. Both 11J Reporting &I.imit violations 9c. > 0
10. Number of SIUs in SNC due to IU Reporting violations
that were not sampled or inspected by POTW 10.=> Q SNIN
11. Number of SIUs in SNC due to violation of 11.=> Q SSNC
Compliance Schedule due dates
12. Number NOVs,NNCs,AOs, or similar assesed to SIUs 12.=> I FENF
13. Number Civil or Criminal Penalties assessed to SIUs 13.=> 0 JUDI
14. Number of Sills included in public notice 14.=> 1 SVPU
15. Number of SIUs from which penalties collected 15.=> 0 NPN
16. Total Amount of Civil Penalties Collected 16.=> $ C)
17. Total Number of SIUs on a compliance schedule 17.=> n sots
Foot Notes: AO Administrative Order NOV Notice of Violation
CIU Categorical Industrial User PAR Pretreatment Annual Report
CO Consent Order POTW Public Operated Treatment Works
IUP Industrial User Pretreatment Permit SIU Significant Industrial User
NNC Notice of Non-Compliance SNC Significant Non-Compliance,formerly RNC
Chapter name: PAR Guidance •
File name: PAR_PPS.sls Comprehensive Guide, Chapter 9, Section B, Page 5
Revision date:August 1,1994 Blank PPS Form,Copy and use in your PAR

•
Pretreatment Annual Report (PAR) PAR covers this calendar year=> 2,0I
Significant Non-Compliance Report (SNCR) Control Authority=Program=Town Name => ex-son
WWTP= Wastewater Treatment Plant, use separate form for each WWTP. WWTP Name => je..'e ccr W L P
SIU = Significant Industrial User NPDES # => 1dc002170Q
SNC = Significant Non-Compliance
A SNCR Form must be submitted with every PAR, please write "None " if you had No SIUs in SNC during calendar year
SNC ? (Yes/No)
IUP Pipe Industry Name Parameter for each 6-month period.
# # or"Reporting" Jan. -June July -Dec.
001 01 Ayperican Emer5eney Vehtries 1305 1\16 Yes
Attach a copy of the Division's "SIUs in SNC Historical Report" for your POTW's SIUs behind this page .
Is the database correct ? Notify the Division of any errors ! Database indicates SNC history for previous years.
EVERY SNC MUST be explained in the Narrative, How was, is, or will it be resolved?
REPEAT SNCs are serious matters that MUST be explained in the Narrative.
Form name. PAR.SNCR,2001 •
Date Revised 1/4/2001

T chnr.ft o "effercsom ill arae r 1 ell rcj'
1233 Highway 16 South° P.O. Box 67 Jefferson,AyNC 28640 336.246.2165
"Protect"the,New�$e' g Over B 9D
Cathy Howell,Town Manager Tim Church, Director
May 14, 2018
American Emergency Vehicles
165 American Way
Jefferson,NC 28640
ATTN: Mr. Gary Graybeal, Compliance Manager
SUBJECT: Notice of Violation
Significant Non Compliance: BOD July-December, 2017
Gary,
The notice of non-compliance issued to AEV in February, 2018 for BOD violations
during the second semiannual period of 2017 has been reviewed by North Carolina
Division of Environmental Quality. Their findings indicate the levels of BOD in a
sample collected at AEV on November 7, 2017 result in Significant Non Compliance for
the second semiannual period of 2017 for American Emergency Vehicles.
The Town of Jefferson has issued a Public Notice of this violation in the local newspaper.
AEV is requested to submit any BOD data collected in its discharge during the first
semiannual period of 2018 to the Town of Jefferson immediately. This information will
be compiled with sample data collected in May by the Town of Jefferson to determine
present compliance status. The Town also encourages efforts to locate and eliminate
sources of BOD that could be entering the categorical sample site listed in Industrial
Pretreatment Permit#004.
As you are aware, sampling early in the semiannual period and encouraging commercial
laboratories to report analytical results to you as soon as available provides an opportunity
to collect additional re-samples that can provide satisfactory compliance judgment in the
event of analytical data that may be influenced by anomalies.
Thank you for your assistance to the Town of Jefferson as we continue to protect the
waters of the New River Basin. If you have questions regarding this matter, please call
me at [phone].
Sincerely,
neubt
Tim Church, Water Resources Director
Town of Jefferson
[e-mail]

•
•
ft
This Public Notice and the related news article
appeared in the May 16, 2018 editions of the TOWN OF JeFFENSON,
,WATER RESOURCES, r
Ashe Post & Times. PUBLIONOTIOE
The wastewater discharge ,of
American Emergency,Vehicles
to the Town ofJeffersonSani7,_
The newspaper will provide a Publisher's tary Sewer Collection System'
has _determined,to tie
Affidavit to the Town. ,Significant 'Non-con-whencefor
BOD that 'exceeded the limita'
set forth'Wittlin''Iridustriak User,
4 Permit#004 held by'AEV:The'
violation "OccOrred, in isamples'
collected by_the Town pf Jeffer-,
son during.the second semian:-
nual monitoring period of 2017.
Thevielation ,caused 'no 'hart*
'' to the.towri'a collection system
' and caused no excessive levels'
of BOD to be found intheefflu
ent,of the Town of 'Jefferson,-
Wastewater -Treatrnent Plant4
' Efforts are underway to deter;
:mine the,Saurce of-this,,v161a4
tion%
Tira Cnurchr
Water_Resources,DireCtor
' ToWn-of Jefferson'
,May62018,-
•
AEV found to be in significant noa-compliance
oliwg:Aewater i scia.arge iolicy
„ • BY LEE SAii1DERLIN ,nual water monitoring period of 2o17., they have issues with that paparemeter.
-"I
_ 63,,figthePosto*Osnm BOD is the amount of dissolved oxygen Its not that common(to have sampling
needed byaerobiebiOlogical organisms to- anomalies),but sometimes we'haVe
JEFFERS034'-'-:Ather,ican Einergency, break;doW,Udrganiematerial present in a ''numbers that will high and reqUire
Vehicles Wns found to be in significant' :griven Water samplt additional sampling to get their lumber's
-non-compliance oftown of jefterSOn; Church said that he belieye.sAV'S high back into compliance and usually that
, •
;wastewater discharge policy,according to BODnumbers to be an"anomaly,”but solves the problem.,"
Jefferson Water Resources Director'Tim :that additional testing will conducted. Church also stated that there was no
, church; .; , 'From time e to time,arimdus, ;4amage'tothe town's collection system „
ABY'hadhighlevelsofbioclierniCalj,)' SamPle`apd'comeup with some high num- and that there were no excessive levels
oxygen demanding Pollutantsin its water bets and AEV has Same high numbers, BOD to be found in'the'efilaeht of the
samples from Jefferson's second seniian- . Church said."I have no reason to believe town's Wastewater treatment plant ',1
. ,„