NC0021709_Pretreatment Audit Inspection Report and NOV_20190329

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Mr. Tim Church, Pretreatment Coordinator
Town of Jefferson
P.O. Box 67
Jefferson, NC 28640
NORTH CAROLINA
Environmental Quality
March 29, 2019
SUBJECT: Pretreatment Audit Inspection Report and Notice of Violation
NOV Tracking No. NOV-2019-PC-0211
Jefferson Wastewater Treatment Plant
NPDES Permit No. NCO021709
Ashe County
Dear Mr. Church,
On March 12, 2019, Paul DiMatteo of this office and Vivien Zhong of PERCS conducted a Pretreatment Audit
Inspection at the above referenced wastewater treatment system. Tim Church, Pretreatment Coordinator, was present
for the inspection. The purpose of this inspection was to determine the effectiveness of the pretreatment program,
which included: a detailed file review, review of the POTW facility performance, sampling and compliance judgement
program, adherence to the enforcement response plan, and observing an industrial user inspection.
Background
The County operates a 0.600 MGD wastewater treatment facility and has one significant industrial user.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on August 3, 2018 and was approved on August 7, 2018.
The next HWA is due by April 1, 2022.
The last Industrial Waste Survey (IWS) was submitted on May 27, 2014 and was approved on August 4, 2014.
The next IWS is due by May 1, 2019.
2018.
The last Short -Term Monitoring Plan (STMP) was submitted on March 16, 2018 and was approved on March 28,
The Sewer Use Ordinance (SUO) was submitted on November 2, 2012 and approved on November 7, 2012.
The Enforcement Response Plan was approved on April 7, 2003.
STMP Review
The STMP is being conducted at the proper locations and frequencies
D E Q�p North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27105
NORTH C. 0LINA
o•o•°^•mme""°""•"viu"•i� /� 336.776.9800

Industrial User Permit OUP) File Review
A review of the files for American Emergency Vehicles (#004) revealed that the monitoring data was well
organized and the slug control plan was in good order.
Industrial Inspection
American Emergency Vehicles is an ambulance manufacturer that has a categorical waste stream regulated
under 40 CFR 433. The inspection included a thorough review of the plant, sampling practices, and industry self -
monitoring.
Summary of Non -Compliance
A review of the Industry's monitoring data and Jefferson's Pretreatment Annual Report revealed that several pH
limits violations across both semiannual periods in 2018. However, the POTW did not conduct or require resampling,
and did not send any enforcement Notice until the Annual Report was prepared. Please note that the approved
Enforcement Response Plan's procedures for addressing violations includes time frames for sending notices and
requirements for resampling. The ERP must be followed when addressing such violations.
Mr. Church discussed plans to achieve pH compliance with Inspectors and the Industry. Please note that changes
to the sampling point should be reflected in the Industrial User Permit. Ms. Zhong also suggested updating the ERP, as
the Division's current model plan incorporates longer time frames for addressing violations.
Follow -Up Actions
The Town's Allocation Table shows an over allocation of cyanide and silver. Ms. Zhong and Mr. Church explained
that these "paper over allocations" could be resolved with an IUP modification. Please finalize the modification by April
15, 2019.
Please note that the updated IWS must be submitted by May 1, 2019.
Finally, please be sure to take appropriate enforcement action as specified in the manner and time frames
specified in the ERP.
If you should have any questions regarding this report, please do not hesitate to contact Paul DiMatteo at (336)
776-9691 or our office at [phone].
Sincerely,
DocuSigned by:
J� T SMdcr
-4'B49E225C94EA...
Lon T. Snider, Assistant Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Enclosures — PAI Report
CC: PERCS Unit — Vivien Zhong
WSRO Files
Central Files