NC0021709_Response to Notice_20240903

Charity Shadcy �FER p Peter Eller
Town Manager ` Mayor
Kayla Jones �T Aldermen
Finance Officer - CAR0V� Charles Caudill
Cathy Ballou
[phone] THE TOWN OF J EFFERSON ,John Shepherd
NvNvw.to\vnofjcffcrsnn.org 302 East plain Strcct Judson Blevins
.Jefferson, NC 28640
September 3, 2024
Lon T. Snider, Regional Supervisor
North Carolina Department of Environmental Quality, Division of Water Resources
Winston-Salem Regional Office
450 West Hanes Mill Road, Suite 300
Winston-Salem, North Carolina 27105
SUBJECT: Notice of Violation & Intent to Assess Civil Penalty
Tracking Number: NOV-2024-LV-0747
Permit No. NC0021709
Jefferson WWTP
Ashe County
Dear Mr. Snider:
The Town of Jefferson submits the following information regarding the Notice of Violation
mentioned above, specifically the Daily Maximum and Monthly Average exceeded for Total
Copper in an effluent sample collected 5/31/2024,
This information will hopefully indicate the violation has been corrected and that it is not of an
ongoing nature based on the following analytical results from the Jefferson WWTP effluent since
the violation occurred in May, 2024. The Daily Maximum Limit is 21.6 and the Monthly Average
Limit is 17.6.
DATE Effluent Copper Result, ug/I
June 4, 2024 13.
July 24, 2024 - <10.
August 12, 2024 11.

The following information is presented to indicate the Town's recent history of permit
compliance in regard to effluent copper.
DATE Effluent Copper Result, ug/I
January 3, 2024 11.
February 21, 2024 10,
March 5, 2024 <10.
April 3, 2024 11.
The Jefferson WWTP collected a sample to be analyzed for copper on May 8, 2024.
In the last week of May we learned that this sample had been lost. The repeat sample was
collected on May 31. We cannot offer a plausible explanation as to why this sample was found
to contain copper at the value of 222. ug/I, in light of the low concentration of copper in the
samples collected prior and subsequent to the violation. We believe this result to be abnormal
and does not accurately reflect the nature of the WWTP discharge. The routine Chronic Toxicity
analysis of the WWTP effluent for sampling conducted May 6 through May 8 passed.
The level of copper measured in the discharge of the only Significant Industrial User in the
Town's collection system has demonstrated a history of compliance with the copper limit in its
Industrial User Permit and due to the nature of its operation, it is considered to be an unlikely
source of copper to the WWTP.
Jefferson Water Resources will continue to be alert to possible sources of copper in its collection
system and will attempt to complete sampling as early as possible each month of the WWTP
discharge to allow time for resampling, as conditions require. It is our hope the information
offered will be satisfactory to indicate this situation is resolved.
Thank you for your consideration.
Respectfully,
f��e1wil'-Z
Tim Church, Water Resources Director
Town of Jefferson
Charity Shatley, Jefferson Town Manager