NC0021709_Pretreatment_Annual_Report_Revision_20240327

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. Pretreatment Town Name: Town of Jefferson
2. "Primary" NPDES Number NC00 21709
or Non-Discharge Permit# if applicable =>
3. PAR Begin Date, please enter 01/01/yyyy 3.=> l/l/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 of CIUs 6.=> 1
7. Number of SIUs with no IUP, or with an expired IUP 7.=> 0
S. 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 lUs from which penalties collected 20.=> 0
Foot Notes: AO Administrative Order IUP Industrial User Pretreatment Permit POTW Publicly Owned Treatment Works
CIU Categorical Industrial User NNC Notice of Non-Compliance SIU 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 IWC % at 7Q10 29.69
WWTP Name Town of Jefferson Stream Information
Program Approval Date 01/20/1988 7Q10 Flow cfs/ mgd 2.2 / 1.42
Pretreatment Status 1010 Flow cfs/ mgd 1.84 / 1.19
Modified Stream Classification C+
Region WSRO Basin Number NEW01
County Ashe 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 Current Fiscal 12/06/2021 required
p 03/31/2022 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)
W 005
WTP SIU's 1 Program SIUs 1
WWTP CIU's 1 Program CIUs11 HWA LTMP IWS 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
Date Date Date
PT_Pro Attended Attended Attended
Formal Name 9-Prime Phonel ext Fax HWA Wksp IUP Wksp PAR Wksp
Mr. Tim Church lPrim [phone] 1 1(336) 246-2165 8/22/2007 1 1/23/2001
[e-mail] Water Resources Director PO Box 67 28640
Mr. Michael Whittenburg 1 11(828) 252.0575 177
[e-mail] Engineering Associate
Pretreatment Related NOVs from DWQ DWR Central Office Contact JPretreatment Staff
1/14/2005 SIU inspections, enforcement lex Lowe
DWR Regional Contact
7/13/2010 NOV/NOI, 6/17/10 PCI, failure to enforce
5/23/2014 NOD

Charity Shaticy � Peter Idler
Town Manager Mayor
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Kayla joncs �0
finance Officer CAR0
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[phone] 1­111:1-OWN OF.)FFFFRSONSPA
\N,",\\•.to,,,,,nofjefferson.org 302 East \lain Street '
Jefferson, \'C 28640
March 7 2024 Wwrm
Copy
American Emergency Vehicles Certified Mail 9589 0710 5270 1200 1396 58
101 AEV Lane Return Receipt Requested
Jefferson, NC 28640
ATTN: Mr. Gary Graybeal, Compliance Manager
SUBJECT: Industrial Pretreatment Permit Number 004
NOTICE OF VIOLATION/SIGNIFICANT NON-COMPLIANCE
Zinc/Total Suspended Solids for Semiannual Period July through December, 2023
Dear Mr. Graybeal:
On August 8, 2023 a self-monitoring sample of the discharge of American Emergency Vehicles to the Town
of Jefferson sanitary sewer system contained Zinc at a concentration of 5.72 mg/l. This was a violation of
the daily maximum limit for Zinc (2.61 mg/1) found in Industrial User Permit 004 held by AEV. This
concentration also represents a violation of the Technical Review Criteria limit of 3.12 mg/I. Using
additional results from samples collected November 8, 2023 and November 20, 2023, the calculations
from the Compliance Judgment Worksheets indicated American Emergency Vehicles to be in Significant
Non-Compliance for Zinc in this semiannual period.
Also, on August 8, 2023 a self-monitoring sample of the discharges of American Emergency Vehicles
contained Total Suspended Solids at a concentration of 4,476 mg/I. This was a violation of the monthly
average limit of 300. mg/I. This concentration also represents a violation of the Technical Review Criteria
limit of 420 mg/l. Using additional results from samples collected November 8, 2023 and November 20,
2023, the calculations in the Compliance Judgment Worksheets indicated American Emergency Vehicles
to be in Significant Non-Compliance for Total Suspended Solids in this semiannual period.
Based upon the Town of Jefferson Enforcement Response Plan a permit violation resulting in Significant
Non-Compliance can result in a civil penalty of up to $25,000.00.A Public Notice is also required and will
be published for this violation. Due to the costs of administering Notices of Violation, future violations
resulting in Significant Non-Compliance may result in the assessment of civil penalties.
American Emergency Vehicles is required to collect an additional sample for Zinc and Total Suspended
Solids prior to April 30, 2024.

Please find attached the Compliance Judgment Worksheets including the calculations used to determined
compliance with Industrial User Permit during six-month periods. It is important for personnel involved in
pretreatment to be familiar the Industrial User Permit limits and the criteria which determines compliance.
Collecting samples early in each compliance period will allow the industry to receive analytical results
sooner and become aware of issues that may require additional sampling to achieve compliance with
permit limits. Sometimes an additional sample may return the industry to compliance.
Pretreatment personnel are welcome to contact me any time about compliance calculations, questions
about how to maintain compliance, and whether additional sampling is needed.
If you have questions regarding this correspondence please contact me at [phone] or by email at
[e-mail]. Thank you for your assistance to the Town of Jefferson Water Resources as we
continue to protect the waters of the New River Basin.
Sincerely,
-7a4..,, RAv�
Tim Church, Water Resources Director
Town of Jefferson
CC: Charity Shatley,Jefferson Town Manager
UNITED STATES
POSTAL SERVICE.
JEFFERSON
PostalService" 410 E MAIN ST
� CERTIFIED o JEFFERSON• NC 28640-8985
RECEIPT [phone]
Domestic Mail Only 03/08/2024 02:39 PM
m Product Qty Unit Price
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C3 Certified Mail Fee
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t�t!_! 0640 First-Class Mail® 1 $1.63
Extra Services&Fees(check box,add fee 'p_ ate) r�1 Large Envelope
❑Re .Receipt(hardcopy) $ I I !!I! Jefferson, NC 28640
C3 ❑Return Receipt(electronic) $ 4.11•111-1 Postmark Weight: 0 lb 1.60 oZ
C`- ❑Certified Mall Restricted Delivery $�)^r w I,1(! Here Estimated Delivery Date
nu ❑Adutt Signature Required $ _
Lr1 ❑Adult Signature Restricted Delivery$ Mon 03/11/2024
Postage Certified Mai 1 @ $4.40
C3 $ _" Tracking #:
rq Total Postage and Fees �!3/ !8`?l!2k 9589 0710 5270 1200 1396 58
C3 $ ',.r Return Receipt $3.65
seDrra Tracking #:
��/)n__ YpQ�` �____�$________j__ 9590 9402 8631 3244 3551 29
$treat anPAKfT_,or box Nb.'� r�* Total $�'6s
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City,State,ZIP+4® �Q
PS Form 3800,January r ,r ,rr•r• Grand Total : $9.68
---- -'
Cash $10.00
Change -$0.32
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STATE OF NORTH CAROLINA
ASHE COUNTY -
TOWN OF JEFFERSON
WATER RESOURCES
PUBLIC NOTICE
TOWN OF JEFFERSON Wastewater discharged by
American Emergency Vehicles
PO Box 67 to the Town of Jefferson sewer
collection system on August 30,
Jefferson,NC 28640-0067 2023 contained Zinc and Total
Suspended Solids in concentra-
tions that exceeded the limits of
the Inustrial User
AFFIDAVIT OF PUBLICATION Permit held by AEV.retreatment
The Town of Jefferson issed a
Notice of Violation to AEV for
Before the undersigned,a Notary Public of said County and State,duly commissioned, Significant Non compliance.The
;" violation caused no harm to the
qualifi authorized�lyv�aw T administer oaths,personally appeared Town's collection system,treat
�r lliLjA�� �� i�T;C/A who bein first dul sworn de oses and sa s:that charmen plant, or its effluent dis
g Y � p Y charge.
he(she)is an employee ofADAMS PUBLISHING GROUP,LLC,engaged in the publication
of a newspaper known as Ashe Post&Times,published in the city of WEST JEFFERSON
in said County and State,that he(she) is authorized to make this affidavit and sworn statement;
that the notice or other legal advertisement,a true copy of which is attached hereto,was
published in Ashe Post&Times,a newspaper meeting all of the requirements and
qualifications of Section I-597 of the General Statues of North Carolina on the following dates:
Notice of Violation to AEV
03/13/24
Ashe PostJimes
P.O.BOX 1815,BOONE,NC 28607
828-264-6397
­)oN.M• t^�''., This 13th day of arch, 2024
�?:'�pTARy'•.�� i �i�.. � lkti
Signature of person making affidavit
yA•••'°(I B LAG _ Sworn to and ed before me on this 13th day of March,2024
yG.� .•;�A QA COV ��:
Notary Public
My Commission ex pires: