NC0021709_Pretreatment_PAI_Report_20240905

Docusign Envelope ID:867B823E-04BB-4ADE-A473-DDE8ACB8ED06
t�E STATE aF�
h y
ROY COOPER
Governor
ELIZABETH S.BISER
Secretary
RICHARD E.ROGERS,JR. NORTH CAROLINA
Director Environmental Quality
9/5/2024
Via Electronic Mail(jeffwns(c�r�,centurylink.net)
Mr. Tim Church
Water Resources Director
Town of Jefferson
302 East Main Street
Jefferson,NC 28640
Subject: Pretreatment Audit Inspection
Program: Town of Jefferson
Wastewater Treatment Plant: Town of Jefferson WWTP
NPDES #: NC0021709,Ashe County
Dear Mr. Church:
Enclosed is a copy of the Pretreatment Audit Inspection(PAI)Report for the inspection of the Town of Jefferson's
industrial pretreatment program on June 19,2024,by Mr. Keyes McGee of the Division's Central Office.
Background
The Town of Jefferson has one categorical industrial user (CIU) discharging effluent to the Town of
Jefferson Wastewater Treatment Plant.
Publicly Owned Treatment Works (POTW)Interview
Discussions with you indicate no POTW issues related to the pretreatment program at the time of this
PAI.
Pretreatment Program Elements Review
The most recent Headworks Analysis (HWA) was submitted to the Division on March 30, 2022, in
response to the NPDES permit renewal effective November 1, 2023. The HWA is awaiting Division
review.
The Industrial Waste Survey(IWS)was approved on May 30,2019.
The Sewer Use Ordinance(SUO)was approved on November 7,2012.
The Enforcement Response Plan(ERP)was approved on September 23,2020.
The Short Term Monitoring Plan(STMP)was approved on March 28,2018.
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh,North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
Uapad—t of E,,kommntal Quay

Docusign Envelope ID:867B823E-04BB-4ADE-A473-DDE8ACB8ED06
STMP File Review Findings
The POTW is sampling as per the approved STMP at the appropriate PQLs.
Industrial User Permit(IUP) File Review
File review for American Emergency Vehicles [AEV] (004)indicates well organized records and data.
The SILT was SNC for the last complete 6-month reporting period for Zinc and TSS exceedances. The
control authority followed the ERP properly to respond to the violations.
POTW Industrial Inspection Review
The POTW annual on-site inspection of AEV was witnessed by the Division and it was completed as
required.
File No Action Items Necessary for the Pretreatment Program
Final Comments
The Town of Jefferson's industrial pretreatment program is satisfactory. The POTW continues to
administrate an adequate pretreatment program.
Please inform the control authority's most senior management of our findings by forwarding a copy of this letter
and the enclosed report.
The report should be self-explanatory; however, should you have any questions, please do not hesitate to contact
Mr. McGee at(919) 707-3636, email: ke, e�gee(rdeq.nc.gov.
Sincerely,
tkm/j efferson_pai_2024
DocuSigned by:
Enclosure: 06/19/2024 Inspection Report E�� �. L �_�
Ec: Municipal Unit File Kh
Jenny Graznak,WSRO C464531431644FE...
Central Files(Laserfiche) Michael J. Montebello,NPDES Branch Chief
Division of Water Resources
D E Q North Carolina Department of Environmental Quality I Division of Water Resources
vvv512 North Salisbury Street 11611 Mail Service Center I Raleigh,North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
Depa"mem of Environmental Duality

Docusign Envelope ID:867B823E-04BB-4ADE-A473-DDE8ACB8ED06
i
a NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resources
ENVIRONMENTAL QUALITY
Background Information [Complete prior to audit; review Program Info Database Sheet(s)l
1. Control Authority(POTW)Name: Town of Jefferson
2. Control Authority Representative(s):Tim Church
3. Title(s):Water Resources Director&Pretreatment Coordinator
4. Address of POTW:
Mailing PO Box 67
City Jefferson Zip Code 28640
Phone Number [phone] Fax Number E-Mail jeffwnsAcenturylink.net
5. Audit Date 06/16/2024
6. Last Inspection Date: 12/16/2021 Inspection Type: ®PCI ❑Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ®Yes ❑ No
If No,Explain.PPID was updated because HWA was submitted 3/30/2022 and there's not a copy of it in the public
record—it will be resubmitted.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ❑Yes ® No
If Yes,Explain.BOD in April 5.1 mg/1 average(corrected in May); all metals good; sludge quality good(land
application of class B liquid sludge).
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑Yes ❑ No ® NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number MM/DD/YY
INIC101012 11 17 IO 19 1 16 1191241
_10:..Current Number of Significant.Industrial Users(SIUs) ............................................................................................................................. 1
11. Number of SIUs with No IUP,or with an Expired IUP?............................................................................................................................. 0
................................................................................ . .............................................
12. Number of SIUs Not Inspected.by POTW in Last Calendar Year? 0
.................................................................................................................................................
1.3. Number of SIUs Not Sampled by POTW in.Last Calendar Year? 0
......................................................................................................................................................
14. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi-Annual Periods? 0
15. Number of SIUs in SNC for Reporting.During Either of Last 2 Semi-Annual Periods? 0
16. Number of SIUs in SNC with Pretreatment Schedule? 0
......................................................................................................................................................................................................................................................................................................
17. Number of SIUs on Schedules? 0
......................................................................................................................................................................................................................................................................................................
_1$:.._Current Number of Categorical Industrial Users..(CIUS) .......................................................................................................................... 1
19. Number of ClUs in SNC? 0
NC DWR Pretreatment Audit Form Revised: July 2024 Page 1

Docusign Envelope ID:867B823E-04BB-4ADE-A473-DDE8ACB8ED06
20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program
Element in their File,complete with all supporting documents and PERCS Approval Letter,and dates consistent with Program Info:
Program Element Last Submittal Last Approval Date Next Due,
Date In file? Date In file If Applicable
Headworks Analysis(HWA) 03/30/2022 ®Yes ❑ No N/A ❑Yes ® No TBD
Industrial Waste Survey(IWS) 04/25/2019 ®Yes ❑ No 05/30/2019 ®Yes ❑ No N/A
Sewer Use Ordinance(SUO) 11/02/2012 ®Yes ❑ No 11/07/2012 ®Yes ❑ No TBD
Enforcement Response Plan(ERP) 06/29/2020 ®Yes ❑ No 09/23/2020 ®Yes ❑ No TBD
Long Term Monitoring Plan(LTMP) 03/28/2018 ®Yes ❑ No 03/28/2018 ®Yes ❑ No N/A
Legal Authority(Sewer Use Ordinance-SUO)
21. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
❑Yes ® No If yes,Please list these towns and/or areas.
22. If yes to#21,Do you have current Interjurisdictional Agreements(IJAs)or other Contracts? ❑Yes❑ No ®NA
A copy,if not already submitted,should be sent to Division.
23. If yes to#21,Have you had any trouble working with these towns or districts? ❑Yes ❑ No ®NA
If yes,Explain.
24. Date of Last SUO Adoption by Local Council 11/20/2023
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑Yes® No
If yes,Explain.
Enforcement(Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? ®Yes ❑ No
If no,POTW must send copy within 30 days.
27. Have you had any problems interpreting or enforcing any part of the ERP(i.e. any adjudication,improper enforcement,etc?
❑Yes ® No If yes,Explain.
28. List Industries under a Schedule or Order and Type of Schedule or Order
N/A
Resources
29. Please Rate the Following: S=Satisfacto M=Mar final U=Unsatisfactory
Rating Explanation,if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program ®S ❑M❑U
Access to POTW Vehicles for
Sampling,Inspections,and ®S ❑M❑U
Emergencies
Access to Operable Sampling
Equipment ®S ❑M❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis ®S ❑M ❑U
Reference Materials
®S ❑M ❑U
Staff Training(i.e.Annual and
Regional Workshops,Etc.) ®S ❑M❑U
Computer Equipment(Hardware and
Software) ®S ❑M❑U
NC DWR Pretreatment Audit Form Revised: July 2024 Page 2

Docusign Envelope ID:867B823E-04BB-4ADE-A473-DDE8ACB8ED06
30. Does the POTW have an adequate data management system to run the pretreatment program?®Yes ❑ No
Explain Yes or No.
31. How does the POTW recover the cost of the Pretreatment Program from their industries?Explain.
Rates are adequate to fund the pretreatment program.
Public Perception/Participation
32. Are there any local issues affecting the pretreatment program(e.g..odor,plant closing,new or proposed plants)?
❑Yes ® No If yes,Explain.
33. Has any one from the public ever requested to review pretreatment program files? ❑Yes ® No
If yes,Explain procedure.If no,how would the request be addressed?
34. Has any industry ever requested that certain information remain confidential from the public? ❑Yes® No If yes,Explain
procedure for determining whether information qualified for confidential status,as well as procedure for keeping files confidential
from public. If no how would the request be addressed?
35. In addition to annual inspection,does the POTW periodically meet with industries to discuss pretreatment? ®Yes ❑ No
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No - [In meeting agenda]
37. Were all industries in SNC published in the last notice? ®Yes ❑ No - [See 2023 PAR for last SNC notice]
Permitting(Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users?Water meter or sewer tap applications/
39. Once the POTW becomes aware of new or changed Users,how does the POTW determine which industries have the
reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an
SIU?)Start by sending the short form.
40. Does the POTW receive waste from any groundwater remediation projects(petroleum,CERCLA)or landfill leachate?
®Yes❑No If Yes,How many are there?Accepting Ashe County Landfill leachate.
Please list each site and how it is permitted,if applicable.Under a local permit
41. Does the POTW accept waste by(mark if applicable) ®Truck ❑Dedicated Pipe ❑NA
42. If the POTW accepts trucked waste,what controls are placed on this waste? (example.designated point, samples drawn,
manifests required)Trucked leachate is discharged into a designated manhole.
43. How does the POTW allocate its loading to industries?Mark all that apply
❑Uniform Limits ®Historical Industry Need ❑ By Surcharge ❑ Categorical Limits ❑ Other
Explain Other: POTW flexibility because of having only 1 SIU.
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations`? ❑ Ycs ® No
If yes,what parameters are over allocated?N/A
45. If yes to#44,What is being done to address the over allocations?(short-term IUPs,HWA to be revised,pollutant study,etc.)
N/A
46. Does the POTW keep pollutant loading in reserve for future growth/safety? ❑Yes ® No
If yes,what percentage of each parameter N/A% [No criteria to determine that]
47. Has the POTW experienced any difficulty in allocation?(for example: adjudication by an industry) ❑Yes ® No
If yes,Explain.
48. How does the POTW decide on which pollutants to limit in the permits?Monitor for? (for example:were only those pollutants
listed on the application limited;categorical parameters;NPDES Pollutants of Concern)
Based upon the most recent HWA.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Historical precedent.
NC DWR Pretreatment Audit Form Revised: July 2024 Page 3

Docusign Envelope ID:867B823E-04BB-4ADE-A473-DDE8ACB8ED06
Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No
If yes,which industries? What was(will be)the outcome of the adjudication?
51. Demonstrate how the POTW judges compliance.This should include compliance judgment on all violations of limits,reporting
requirements,and permit conditions,as well as for SNC.Timely evaluation of sampling data.
52. Does the POTW use the Division's model inspection form or equivalent? ®Yes ❑ No
If no,does the POTW form include all Division data? ❑Yes ❑ No -[N/A]
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ®Yes❑ No
If no,Explain.N/A
54. What criteria are used to determine if a slug/spill control plan is needed?
AEV's 14001 ISO EMS requires this with periodic management review.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Review of periodic reports submitted to the POTW.
56. How does the POTW decide where the sample point for an SIU should be located?
It is representative of the categorical flow.
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: correct location;proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: ®Yes❑ No SIU: ®Yes ❑ No If yes,Explain.Preventing getting sump solids in the line.
58. Who performs sample analysis for the POTW for Metals Water Ouality Labs,Banner Elk
Conventional Parameters Water Ouality Labs,Banner Elk
Organics Water Ouality Labs,Banner Elk
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
This was thoroughly and satisfactorily explained.
Long/Short Term Monitoring Plan(L/STMP)and Headworks Analysis(HWA)
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ®YES ❑NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ®YES ❑NO Is Table Adequate? ®YES ❑NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report(DMR)?®YES ❑NO Division Inspector,verify yourself.
60e. If NO to any above,list violations
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑YES ®NO
If yes,which ones?Eliminated: Added:
61. Do you complete your own headworks analysis(HWA)? ❑Yes ® No
If no,who completes your HWA?Withers&Ravenel Phone[phone]
62. Do you have plans to revise your HWA in the near future? ®Yes ❑ No
If yes,what is the reason for the revision?(mark all that apply) ❑Increased average flow ❑NPDES limits change
❑More LTMP data available ❑Resolve over allocation ®5 year expiration ❑Other
Explain.
63. In general,what is the most limiting criteria of your HWA? ❑Inhibition ❑Pass Through ®Sludge Quality
64. Do you see any way to increase your loading in the future(Example: obtaining more land for sludge disposal)? ❑Yes® No
Explain.No possibility.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
None
NC DWR Pretreatment Audit Form Revised: July 2024 Page 4

Docusign Envelope ID:867B823E-04BB-4ADE-A473-DDE8ACB8ED06
INDUSTRIAL USER PERMIT IUP FILE REVIEW 3 IUP FILE REVIEWS AND 1 IU INSPECTION
66. User Name 1.American Emergency 2. 3.
Vehicles
67. IUP Number 004
68. Does File Contain Current Permit? ®Yes ❑ No ❑Yes ❑ No ❑Yes ❑ No
69. Permit Expiration Date 07/31/2026
70. Categorical Standard Applied I.E.40 CFR,Etc. Or N/A 433.17
71. Does File Contain Permit Application Completed Within One Year Prior ®Yes ❑ No ❑Yes ❑ No ❑Yes ❑ No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year? ®Yes ❑ No El Yes ❑ No El Yes El No
73. a.Does File Contain Slug/Spill Control Plan? a. ZYes❑No a. ❑Yes ❑No a. ❑Yes❑No
b.If No,is One Needed? See Inspection Form from POT b. ❑Yes ❑No b. ❑Yes ❑No b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic Yes ❑Yes❑No❑N/A ❑Yes❑No❑N/A
Organic Management Plan TOMP ?
75. a.Does File Contain Original Permit Review Letter from Division? a. ZYes❑No a. ❑Yes ❑No a. ❑Yes❑No
b.All Issues Resolved? b.N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A
76. During Most Recent Semi-Annual Period,Did POTW Complete its ®Yes ❑ No ❑Yes ❑ No ❑Yes ❑ No
Sampling as Required by IUP,including Flow?
77. Does File Contain POTW Sampling Chain-Of-Custody Forms? ®Yes ❑ No ❑Yes ❑ No ❑Yes ❑ No
78. During Most Recent Semi-Annual Period,Did SIU Complete its ®Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
Sampling as Required b IUP,includingFlow? 11
79. During Most Recent Semi-Annual Period,Did SIU submit all reports on ®Yes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
time?
80a.For categorical IUs with Combined Wastestream Formula(CWF),does ❑Yes❑No ZN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
file include process/dilution flows as Required b IUP?
80b.For categorical IUs with Production based limits,does file include ❑Yes❑No ZN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi-Annual Period,Did POTW Identify All ®Yes ❑ No ❑Yes ❑ No ❑Yes ❑ No
Limits Non-Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi-Annual Period,Did POTW Identify All ZYes❑No❑N/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
Re ortin Non-Com liance from SIU Sampling?
83. a.Was POTW Notified by SIU(Within 24 Hours)of All Self- a.®Yes❑No❑N/A a.❑Yes❑No❑N/A a.❑Yes❑No❑N/A
Monitoring Violations? b.®Yes[]No❑
b.Did Industry Resample and submit results to POTW within 30 Days? N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A
c.If applicable,did POTW resample and obtain results within 30 days of
becoming aware of SIU limit violations in the POTW's sampling of SIU? c.❑Yes®No❑N/A c.❑Yes❑No❑N/A c.❑Yes❑No❑N/A
84. During Most Recent Semi-Annual Period,Was SIU in SNC? I ®Yes ❑ No 11 ❑Yes ❑ No ❑Yes ❑ No
85. During Most Recent Semi-Annual Period,Was Enforcement Taken as ❑Yes❑No ZN/A ❑Yes❑No❑7FY7es❑N oEIN/A
Specified in POTW's ERP OVs,Penalties,timing,etc.)?
86. Does File Contain Penalty Assessment Notices? ❑Yes❑No ZN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection? []Yes❑No ZN/A ❑Yes❑No❑N/A ❑Yes❑No❑N/A
88. a.Does File Contain Any Current Enforcement Orders? a.❑Yes[]No ZN/A a.❑Yes❑No❑N/A a.❑Yes❑No❑N/A
b.Is SIU in Compliance with Order? b.[]Yes❑No ZN/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested ❑Yes ® No ❑Yes ❑ No ❑Yes ❑ No
Information For You?
FILE REVIEW COMMENTS:
In 2"half of 2023 NOV was issued to AEV for Zinc violation and TSS.Public Noticed in March 2024.
NC DWR Pretreatment Audit Form Revised: July 2024 Page 5

Docusign Envelope ID:867B823E-04BB-4ADE-A473-DDE8ACB8ED06
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I NI C1 0 1 0 12 11 1 7 1 0 19 1 1 06 1 19 1 241
1.Industry Inspected: American Emergency Vehicles
2.Industry Address: 101 AEW Lane,Jefferson,NC 28640
3. Type of Industry/Product: Medium-Duty Ambulances
4.Industry Contact: Gary Graybeal Title: EHS Manager Phone: [phone] Fax:
5.Does the POTW Use the Division Model Inspection Form or Equivalent? ®Yes ❑ No
6.Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview ®Yes ❑ No
B. Plant Tour ®Yes ❑ No
C. Pretreatment Tour ®Yes ❑ No
D. Sampling Review ®Yes ❑ No
E. Exit Interview ®Yes ❑ No
Industrial Inspection Comments:
Excellent Inspection.
Audit SUMMARY AND COMMENTS:
Audit Comments: Recently revised SUO will be submitted soon and may require an ERP update as well.
Soon there will be a sludge pilot test for landfilling sludge.
ERP has been updated recently for oil&grease.
Requirements: None
Recommendations: None
NOD: ❑Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory❑
Audit COMPLETED BY: Keyes McGee DATE: 06/19/2024
XXXX,PERCS,and XXXX, XXXX Regional Office
NC DWR Pretreatment Audit Form Revised: July 2024 Page 6