NC0021709_Response to NOV2020PC0143_20200409

Town of Jefferson Water Re4o- xoak
1233 Highway 16 South P.O. Box 67 Jefferson, NC 28640 336.246.2165
s`PYa c " - tit & New 9 t var Ba* *C
April 9, 2020
Mr. Lon T. Snider, Regional Supervisor
NC Dept. of Environmental Quality
Division of Water Resources
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
SUBJECT: Pretreatment Compliance Inspection Report
NOV-2020-PC-0143
NPDES # NCO021709
Town of Jefferson, Ashe County
Dear Mr. Snider:
ra c �
Environmenteaarralent or
RecelvedQuality
APR 13 2020
Winston-Salem
Regionai Office
The purpose of this correspondence is to address issues related to the Pretreatment Compliance
Inspection at the Town of Jefferson on March 3, 2020 by Mr. Paul Dimatteo. The following actions have
been taken regarding the File Review Comments contained in the inspection report of March 13, 2020.
A Notice of Violation for lead occurring in October, 2019 has been sent to American Emergency Vehicles.
The Notice of Violation also includes a TRC violation for Zinc that occurred in December, 2020 and resulted
in Significant Non Compliance, requiring a Public Notice to be issued. The Town also suggested the SIU
identify a location upstream of the categorical sampling point for the purpose of verifying adequate pH
adjustment. Measurements of pH taken at the categorical sampling point will continue to be required.
The SIU was also reminded that conducting sampling as early as possible in the compliance period can
contribute to avoiding future SNC situations.
A reminder to date -stamp all correspondence received from American Emergency Vehicles has been
placed in our pretreatment files.
A copy of the NOV issued to American Emergency Vehicles has been enclosed along with the Public Notice
as it will appear in our local newspaper. The Publisher's Affidavit will be provided to the Town.
If you have questions or require additional information please call me at [phone] or contact me at
[e-mail]. Thank you for your assistance to the Town of Jefferson Water Resources
Industrial Pretreatment Program.
Respectfully,
Tim Church, Water Resources Director
Cc: Cathy Howell, Town Manager
ENCL: Notice of Violation to American Emergency Vehicles
Public Notice provided to Ashe Mountain Times

Town of Jefferson W a tee Resourcak
1233 Highway 16 South P.O. Box 67 Jefferson, NC 28640 336.246.2165
March 15, 2020
American Emergency Vehicles
165 American Way
Jefferson, NC 28640
ATTN: Mr. Gary Graybeal, Compliance Manager
SUBJECT: Industrial User Pretreatment Permit # 004
Second semiannual monitoring period: 2019
Notice of Violation for Lead
Notice of Violation for Zinc, SNC requiring Public Notice
Dear Mr. Graybeal:
A self -monitoring sample collected by American Emergency Vehicles in its wastewater discharge on
October 30, 2019 contained lead at a concentration of 0.952 mg/L and was a TRC violation based on the
calculated daily limit of 0.828 mg/L (TRC). Additional samples collected by AEV and the Town of Jefferson
were below the IUP limits for lead. Therefore, a violation of the daily average occurred but did not result
in Significant Non -Compliance for the second semiannual monitoring period of 2019.
A self -monitoring sample collected by American Emergency Vehicles in its wastewater discharge on
December 18, 2019 contained zinc at a concentration of 3.30 mg/L and was a TRC violation based on the
calculated monthly limit of 1.77 mg/L. The monthly average zinc concentration for all samples collected
in December, 2019 was 2.27 mg/L which exceeded the TRC limit of 1.77 mg/L. As a result, American
Emergency Vehicles was in Significant Non -Compliance for zinc for the month of December, 2019. Under
NCDWQ guidelines for Industrial Pretreatment Programs, the zinc violation will result in the issuance of a
Public Notice.
During a recent inspection of the Town of Jefferson Industrial Pretreatment Program by NCDWQ
personnel, the issue of pH adjustment and monitoring of the AEV discharge was discussed. A
determination was made that AEV should identify a sampling point for monitoring pH adjustment in
addition to the sampling/measurement being conducted at the required categorical sampling point. The
pH measurements taken prior to the categorical sampling point could be used for determining needed
changes to pH adjustment and reporting this information to the Town would not be necessary.
The reporting of pH measurements taken at the categorical sampling point will continue to be required.

As discussed in earlier correspondences, sampling early in each semiannual period will allow the industry
additional time to address any violations before they become Significant Non -Compliance.
If you have questions regarding this information please contact me at [phone] or at
[e-mail]. Thank you for your cooperation with the Town of Jefferson Industrial
Pretreatment Program.
Sincerely,
1vr GLVJ"
Tim Church, Water Resources Director
Town of Jefferson
CC: Paul Dimatteo, NCDEQ— WSRO
Cathy Howell, Jefferson Town Manager

From: MOUNTAIN TIMES
Sent: Wednesday, April 8, 2020 8:52 AM
To: [e-mail]
Cc: [e-mail]
Subject: 230909 TOWN OF JEFFERSON WATER RESOURCES NOTICE
Good morning Mr. Church,
The attached is now scheduled to be published 4/1 /20 in the Ashe Post & Times. Please take just a
moment to review.
Thank you,
Brenda
Brenda Minton
Customer Service Team Leader
Mountain Times Publications
C![e-mail]
Office: 828-264-6397 Ext. 714021
.....................
Direct Line: 828-278-3604 Fax: [phone]
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Mountain Times Publications
"Connecting Our Region Through Newsprint and Internet"
Visit us:
www.mountaintimes.com
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www.wataugademocrat.com
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www.ashepostandtimes.com
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www:highcountrxnc _com

MOUNTAIN TIMES
PUBLICATIONS
P.O. BOX 1815
BOONE NC 28607
[phone]
Fax [phone]
ORDER CONFIRMATION (CONTINUED)
Salesperson: BRENDA MINTON Printed at 04/08/20 09:51 by trend-jm
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Acct #: 230909 Ad #: 2079907 Status: New
TOWN OF JEFFERSON
WATER RESOURCES
PUBLIC NOTICE
Wastewater discharged by
American Emergency Vehicles
tot he Town of Jefferson sani-
tary sewer collection system on
December 18, 2019 contained
zinc in a concentration that ex-
ceeded the limits of the Industri-
al User Pretreatment permit
held by AEV.
The violation caused no harm
to the Town's collection system,
treatment plant, or its effluent
discharge. Additional samples
collected and analyzed subse-
quent to this violation have indi-
cated a return to compliance by
the industry.
Tim Church
Water Resources Director
Town of Jefferson
April 2, 2020