NC0021709_Pretreatment_Annual_Report_20240229

Town of Jefferson Water Resources
Industrial Pretreatment Program
ANNUAL REPORT NARRATIVE 2023
The Town of Jefferson Industrial Pretreatment Program regulates American Emergency Vehicles
as its only Significant Industrial User. This facility is a 40 CFR 433.17 categorical metal finishing
operation resulting from a process that uses a fluoridated etching solution to prepare ambulance
bodies for primer coating and finish painting.
The Town of Jefferson samples the AEV discharge semiannually. In 2023 both sampling events
performed by the Town demonstrated compliance with the Industrial User Permit.
AEV also performs sampling of their discharge on a semiannual schedule. All results from the first
sampling event indicated compliance with the IUP. A review of AEV sampling results for the
second semiannual period found levels of Zinc and Total Suspended Solids that exceeded the IUP
limits. Calculations performed through the Compliance Judgment Worksheet also determined
both parameters to be in Significant Non-compliance with Technical Review Criteria. AEV has not
experienced a chronic history of violations in these two parameters. These results may reflect an
anomaly in sampling since no process changes occurred in 2023. The Town of Jefferson and AEV
will collect additional sampling for these parameters.
It is worthwhile to mention that the Categorical process used by AEV results in only a small volume
of discharge to the POTW. The aluminum patient compartment of the ambulance is sprayed with
a light coating of Alumiprep which cleans and preps the unit for the application of a primer coat
and a finish coat of paint. Immediately after application, the Alumiprep is removed using a low
volume of rinse water. The rinse water is collected in a recessed floor drain that surrounds the
application area. The volume of wastewater created is so small that employees are able to contain
it in the drain area before it is discharged to the sewer. From the floor drain it is pumped to a
portable tank mounted on a 1-ton truck. When the tank is full, AEV employees bring it to the
Town WWTP and discharge it to the aerobic digester. The categorical material never enters the
POTW collection system. AEV has tentatively planned to install a permanent in -ground tank to
collect the categorical flow but the Town has cautioned them to delay until NC DEQ comments on
this arrangement. Unless this process would allow AEV to be removed from consideration as a
categorical discharger, it would not be in their interest to proceed.
Meanwhile, based upon its Enforcement Response Plan, the Town of Jefferson has issued a Notice
of Violation to American Emergency Vehicles for Significant Non-compliance (TRC) with IUP limits
for Zinc and Total Suspended Solids for the second semiannual period of 2023. This will also be
accompanied by a Public Notice placed in the Ashe Mountain Times by the Town of Jefferson. AEV
will be required to monitor its discharge immediately (March) and return to compliance. The
Town of Jefferson will also collect additional sampling immediately.

Chapter 9, PAR Guidance
Pretreatment Performance Summary (PPS)
1
2
Pretreatment Town Name: Town of Jefferson
"Primary" NPDES Number NC00 21709
or Non -Discharge Permit # if applicable =>
3.
PAR Begin Date, please enter 01 /01 /yyyy
3. =>
1 /1 /2023
4.
PAR End Date, please enter 12/31 /yyyy
4. =>
12/31 /2023
5.
Total number of SIUs, includes CIUs
5. =>
1
6.
Number ofClUs
6. =>
1
7.
Number of SIUs with no IUP, or with an expired IUP
7. =>
0
8.
Number of SIUs not inspected by POTW
8. =>
0
9.
Number of SIUs not sampled by POTW
9. =>
0
10.
Number of SIUs in SNC due to IUP Limit violations
10. =>
1
11.
Number of SIUs in SNC due to Reporting violations
11. =>
0
12.
Number of SIUs in SNC due to violation of a Compliance Schedule, CO, AO or similar
12. =>
0
13.
Number of CIUs in SNC
13. =>
1
14.
Number of SIUs included in Public Notice
14. =>
1
15
Total number of SIUs on a compliance schedule, CO, AO or similar
15. =>
0
16.
Number of NOVs, NNCs or similar assesed to SIUs
16. =>
1
17.
Number of Civil Penalties assessed to SIUs
17. =>
0
18.
Number of Criminal Penalties assessed to SIUs
18. =>
0
19.
Total Amount of Civil Penalties Collected 19. =>
$
0
20.
Number of IUs from which penalties collected
20. =>
0
Notes:
AO Administrative Order IUP Industrial User Pretreatment Permit POTW
CIU Categorical Industrial User NNC Notice of Non -Compliance SIU
Publicly Owned Treatment Works
Significant Industrial User
CO Consent Order NOV Notice of Violation SNC
Significant Non -Compliance
IU Industrial User PAR Pretreatment Annual Report
revised 1/2018: PAR PPS 2018

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Pretreatment Program Info Database
printed on: 12/22/2023
for Program Name Jefferson
WVVP Name Town of Jefferson
Program Approval Date 01/20/1988
Pretreatment Status Modified
Region WSRO
County Ashe
Stream Information IWC % at 7Q10 29.69
7Q10 Flow cfs / mgd 2.2 / 1.42
1 Q10 Flow cfs / mgd 1.84 / 1.19
Stream Classification C+
Basin Number NEW01
Receiving Stream Name NAKED CREEK
NPDES Number NC0021709
NPDES Effective Date
Last PAR Rec 03/03/2023
PAR Due Date03/01/2024
mercury
02/01 /2018
1631
NPDES Expire Date
p� 03/31 /2022
Current Fiscal 12/06/2021
required
Year PCI Done
POTW is Primary WWTP TRUE
Last Audit on 03/12/2019
Audit Year Nex123/24
yes
Design Flow mgd 0.6000 % Design
mgd is SIU permitted
0.83
Permitted SIU flow (mgd) [Pt_SIU) 005
VWVfP SIU's
1
Program SIUs 1
„
VWVP CIU's
1
Program CIUs 1
HWA LTMP
IWS V SUo
ERP
date Inactive Date Next Due
05/01/2022
Date Received by DWR
08/03/2018 03/16/2018
04/25/2019 11 /02/2012
06/29/2020
Date Approved
08/07/2018 03/28/2018
05/30/2019 11 /07/2012
09/23/2020
Adopt Date Required
Date Adopted
Info in this Box from Pt Contacts
PT —Pro
Formal Name g.Prime Phone1
Mr. Tim Church (Prim II(336) 246-2165
[e-mail]
Mr. Michael Whittenburg I II(828) 252.0575
[e-mail]
Pretreatment Related NOVs from D
1/14/2005
7/13/2010
5/23/2014
ext Fax
1(336) 246-2165
Water Resources Director
177 I
Engineering Associate
Date Date
Date
Attended Attended
Attended
HWA Wksp IUP Wksp
PAR Wksp
8/22/2007 1
1 1 /23/2001
PO Box 67
8640
DWR Central Office Contact JPretreatment Staff
DWR Regional Contact lex Lowe