NC0020389_EAA_20211230

Vooten
TO Division of Water Resources
Compliance and Expedited Permitting Unit
Attn: Sydney Carpenter
[e-mail]
WE ARE SENDING: ® Attached
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DATE December 30, 2021 TWC No.: 2293-CO
RE: Town of Benson
Imposition of Sewer Line Moratorium
Demonstration of Future WWTP Capacity
Engineering Alternatives Analysis
NPDES Permit NC0020389
❑ Under separate cover via the following items:
❑ Plans ❑ Samples ❑ Specifications
❑ Other
DATE
1
DESCRIPTION
Engineering Alternatives Analysis (electronic copy - .PDF)
12/29/2021 Town of Benson WWTP
NPDES Permit NC0020389
THESE ARE TRANSMITTED as checked below:
® For Approval ❑ Reviewed ❑ Revise and Resubmit
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REMARKS:
Cc
Per the letter dated 5/19/2021 (re: Imposition of Sewer Line Moratorium), please find
attached the Engineering Alternative Analysis which demonstrates the future
wastewater treatment capacity needs and proposed action for the Benson WWTP in
accordance with 15A NCAC 02T .0118. The intent of this evaluation was to identify a
viable alternative to meet the future demands of the WWTP via expansion of the
facility in response to the 2020 calendar year flows exceeding 80% of the WWTP
permitted capacity. On behalf of the Town of Benson, upon your review and
concurrence that this document satisfies the requirements of the referenced code,
we request that the sewer line moratorium be lifted.
SIGNED:
Mr. Tim Robbins, Utilities Director Town of Benson
TWC File
Enclosures: as stated via e-mail
If enclosures are not as noted, kindly notify us at once.

ENGINEERING ALTERNATIVE ANALYSIS
FOR
EXPANSION OF DISCHARGE OF WASTEWATER
FROM
TOWN OF BENSON WASTEWATER TREATMENT PLANT
TOWN OF BENSON
JOHNSTON COUNTY, NORTH CAROLINA
December 2021
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CHRISTOPHER J. WHITE, PE
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LICENSE NO. F-0115
TWC 2817-Y

FACILITY INFORMATION
FACILITY NAME: TOWN OF BENSON WASTEWATER TREATMENT PLANT
NPDES PERMIT NO: NC0020389
FACILITY ADDRESS: 770 HANNAH CREEK ROAD
FOUR OAKS, NC 27524
COUNTY: JOHNSTON
UTILITIES DIRECTOR: TIM ROBBINS
TELEPHONE: [phone]
EMAIL: [e-mail]
APPLICANT CONTACT INFORMATION
OWNER: TOWN OF BENSON
CONTACT NAME: FREDERICK NELSON, TOWN MANAGER
ADDRESS: 303 E. CHURCH ST.
BENSON, NC 27504
TELEPHONE: [phone]
EMAIL: [e-mail]
CONSULTING ENGINEER CONTACT INFORMATION
FIRM: THE WOOTEN COMPANY
ENGINEER: CHRIS WHITE, PE
ADDRESS: 120 N. BOYLAN AVE.
RALEIGH, NC 27603
TELEPHONE: [phone]
EMAIL: [e-mail]
Town of Benson - WWTP
Engineering Alternative Analysis
December 2021
XX

TABLE OF CONTENTS
Table of Contents
Index of Tables
Index of Figures
Index of Exhibits
Index of Appendices iv
1.0 INTRODUCTION 1
2.0 ESTIMATED WASTEWATER TREATMENT PLANT FLOWS 5
2.1 Population Projections 5
2.2 Flow Projections 6
2.2.1 Current Flow and Summary of Users 6
2.2.2 Future Flow 6
3.0 ENGINEERING ALTERNATIVE ANALYSIS 8
3.1 Plant Expansion to 3.75 MGD Permitted Capacity (Alt. 1, 2, and 5) 8
3.1.1 Description 11
3.1.2 Construction Cost Opinion 11
3.1.3 Annual Operation and Maintenance Costs 11
3.1.4 Economic Analysis 12
3.2 Alternative 1: Discharge to the Neuse River Basin 12
3.3 Alternative 1A: Expanded Discharge to Hannah Creek 12
3.4 Alternative 1B: Additional Discharge to Stone Creek 13
3.4.1 Description 13
3.4.2 Construction Cost Opinion 13
3.4.3 Annual Operation and Maintenance Costs 13
3.4.4 Economic Analysis 13
3.5 Alternative 1C: Additional Discharge to Neuse River 14
3.5.1 Description 14
3.5.2 Construction Cost Opinion 14
3.5.3 Annual Operation and Maintenance Costs 14
3.5.4 Economic Analysis 14
3.6 Alternative 2: Additional Discharge to the Cape Fear River Basin 15
3.7 Alternative 2A: Additional Discharge to Mingo Swamp 15
3.7.1 Description 15
3.7.2 Construction Cost Opinion 16
3.7.3 Annual Operation and Maintenance Costs 16
3.7.4 Economic Analysis 16
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Engineering Alternative Analysis
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3.8 Alternative 2B: Additional Discharge to Thorntons Creek 16
3.8.1 Description 16
3.8.2 Construction Cost Opinion 17
3.8.3 Annual Operation and Maintenance Costs 17
3.8.4 Economic Analysis 17
3.9 Alternative 2C: Additional Discharge to Cape Fear River 17
3.9.1 Description 17
3.9.2 Construction Cost Opinion 18
3.9.3 Annual Operation and Maintenance Costs 18
3.9.4 Economic Analysis 18
3.10 Alternative 3: Diversion of Influent Flow to Harnett County 18
3.11 Alternative 4: Diversion of Influent Flow to City of Dunn 18
3.12 Alternative 5: Land Application 19
4.0 SELECTION OF ALTERNATIVE 20
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Engineering Alternative Analysis
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INDEX OF TABLES
Table 1 — Population Projections 5
Table 2 — Water Usage Summary of Flows 6
Table 3 — Maximum Month Wastewater Flow 6
Table 4 — Future Flow Projection (2041) 7
Table 5 — Summary of Present Worth Cost Analysis for Alternatives 20
Table 6 — USGS Responses to Low Flow Requests 21
INDEX OF FIGURES
Figure 1 — Population Projections 5
INDEX OF EXHIBITS
Exhibit 1 — Project Location Map 3
Exhibit 2 — Benson WWTP Layout 4
Exhibit 3 — Site Plan Preliminary Layout 10
Town of Benson - WWTP
Engineering Alternative Analysis
December 2021

INDEX OF APPENDICES
APPENDIX A
NPDES Permit NC0020389
NPDES Permit NCCC000001 — Neuse River Compliance Association
APPENDIX B
2018 — 2020 Benson Local Water Supply Plans
2018 — 2021 Benson WWTP Effluent Flow Data
NC OSMB — Population Data
APPENDIX C
Alt. 1 B: Stone Creek Forcemain Alignment Map
Alt. 1 C: Neuse River Forcemain Alignment Map
Alt. 2A: Mingo Swamp Forcemain Alignment Map
Alt. 2B: Thorntons Creek Forcemain Alignment Map
Alt. 2C: Cape Fear River Forcemain Alignment Map
APPENDIX D
Correspondence with DWR (emails)
USGS Responses to Low Flow Requests
Speculative Limits Request for Neuse River Discharge
APPENDIX E
2007 PER — Improvements to Wastewater Treatment Facility (3.0 MGD)
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1.0 INTRODUCTION
The Town of Benson (Town) owns and operates a 1.9-MGD Wastewater Treatment Plant (WWTP) which
provides wastewater treatment for the Town's customers. Exhibits 1 and 2 show, respectively, the vicinity
of the WWTP within the Town and a close-up of the WWTP and its individual components.
The WWTP operates under NPDES permit NC0020389 as a "major" facility (more than 1.0-MGD as
classified by the USEPA). The treatment of wastewater effluent is accomplished through secondary
treatment using three parallel oxidation ditches and solids sedimentation. The treatment train includes
mechanically cleaned bar screen, a manually cleaned bar screen (bypass), a mechanically cleaned grit
removal system, a Parshall flume for influent flow metering, influent wastewater pumping, modified
oxidation ditches for biological nutrient removal, secondary clarifiers, sludge recirculation and waste
pumping, tertiary filtration, chlorine disinfection system, dechlorination system, and post aeration.
Management of the plant is accomplished by Town employees. Sludge solids produced in the WWTP are
processed through an aerated sludge holding basin for long-term sludge stabilization and storage, and
sludge loading station for disposal of stabilized sludge by land application.
The Town of Benson once relied on two large, facultative lagoons to treat its wastewater. The Benson
WWTP consisting of an extended aeration process began operation in 1989 with a permitted monthly
average flow of 1.5 MGD. In 2007, the plant was expanded to a permitted capacity of 1.9 MGD.
The purpose of this document is to evaluate feasible alternatives to expand the treatment capacity and
discharge capacity of the Benson WWTP beyond 1.9 MGD. The Wooten Company prepared a Preliminary
Engineering Report for the Town in 2007 that identified alternatives for an expansion to 3.0 MGD. The
region is experiencing rapid growth and current 20-year flow projections are 3.75 MGD for the Town of
Benson. The current NPDES permit (Appendix A) issued April 2021 notes that the receiving stream is
listed on the North Carolina 303(d) Impaired Waters List for dissolved oxygen. The receiving stream has
been listed on the 303(d) Impaired Waters List for dissolved oxygen since 2004. This document will
therefore focus on treatment options for 3.75 MGD influent to the Benson WWTP with alternative discharge
points, and that the current discharge to Hannah Creek will not exceed the permitted 1.9 MGD. In lieu of
plant expansion, this report also investigates the construction of improvements to enable the Town to divert
as much as 1.85 mgd from the WWTP for treatment elsewhere.
The existing plant average monthly capacity is 1.9 mgd. The Town is permitted to discharge an annual total
nitrogen load of 33,070 Ibs/year after decreasing their allocation by 720 Ibs/year with the sale to Central
Johnston County on 4/2/08 (see the NPDES permit in Appendix A). The Town of Benson has an agreement
with Johnston County to lease the County up to 10,000 Ibs/year of effluent nitrogen allocation (as available
by the Town and as needed by the County) at the prevailing lease rate among members of the NRCA
(Neuse River Compliance Association). The Town has also agreed to receive additional wastewater flow
Town of Benson - WWTP
Engineering Alternative Analysis
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from the County for treatment at its plant. Deducting the maximum leased effluent nitrogen allocation, the
Town of Benson WWTP would need to meet an effluent concentration of less than 4.11 mg/L for total
nitrogen discharged at 1.9 mgd.
Town of Benson - WWTP
Engineering Alternative Analysis
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Town of Benson WWTP
Johnston County, NC
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EXHIBIT 1
Benson WWTP
Project Location Map
Town of Benson - WWTP
Engineering Alternative Analysis
December 2021
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XX

Filters
RAS/WAS
Pump Building
Clarifier Splitter Box
Mechanical Barscreen
Grit Removal System
Chlorine Contact Chamber
Oxidation Ditches
Lift Pump Station
Outfall to Hannah Creek
EXHIBIT 2
Benson WWTP Layout
Town of Benson - WWTP
Engineering Alternative Analysis
December 2021
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2.0 ESTIMATED WASTEWATER TREATMENT PLANT FLOWS
The Town of Benson wastewater flow characteristics include residential, commercial, and industrial
components. The methodology for determining reasonable projection for population and flow can be found
herein. Due to limited 2021 data, the assumptions for flow projections are based on 2020 user information
and metered flows. Appendix B provides supporting data and information for the projections described in
this section.
2.1 POPULATION PROJECTIONS
The Town of Benson is evaluating influent wastewater flow increasing from 1.9 mgd to 3.75 mgd. The
following population projections are based on the historical data obtained from the NC Office of State
Budget and Management (available historical data through 2019) and forecasted linearly based on the prior
10-year data. The evaluation is intended to satisfy a 20-year planning horizon from the time of permit
issuance (i.e., 2021-2041).
Historical Data (NC OSBM)
Year
Population
2010
3,323
2019
3,922
Linear Population Forecast
Year
Population
2021 (Current)
4,122
2041 (Year 20)
6,088
FIGURE 1 — POPULATION PROJECTIONS
7,000
6,000
5,000
c 4,000
0
co 3,000
a
to 2,000
1,000
0
2015 2020 2025 2030 2035 2040 2045
Year
Town of Benson - WWTP
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2.2 FLOW PROJECTIONS
The following sub -sections include justification of flow projections as well as the demonstration of need for
expansion of the current permitted flow.
2.2.1 CURRENT FLOW AND SUMMARY OF USERS
The following table is a summary of water usage flows for the year 2020 as published in the Town's Local
Water Supply Plan.
TABLE 2
— WATER USAGE SUMMARY OF
FL• 77
Type of User
Metered Connections
Metered Average Use (MGD)
Residential
1,600
0.1950
Commercial
293
0.1110
Industrial
3
0.4260
Note — Institutional flows listed in the LWSP are included as part of the commercial flow for the purposes of forecasting projections.
The Town has one significant user that accounts for most of the above listed industrial flows. The Berry
Global plastic manufacturing plant has been discharging an average of approximately 0.300 MGD of
wastewater to the Town collection system and is permitted to discharge a monthly average of 0.400 MGD.
The company has announced an expansion of the facility and has requested increasing their permitted
monthly average discharge to 0.600 MGD with a BOD concentration increase of approximately 20°/0.
The following table indicates the maximum month wastewater flow for each of the last four years at the
WWTP as reported in daily monitoring reports. A copy of the data can be found in Appendix B.
,f_1=1I *el kvi UM iv lilk4i iv [.1 11:ram I ;WA I4:IdglilTJil
Month - Year
Flow (MGD)
December - 2018
1.704
December - 2019
1.554
February - 2020
1.940
February - 2021
2.472
2.2.2 FUTURE FLOW
Per the EAA Guidance Document — October 2019, flow projections represent the average anticipated flows,
and are determined based on the maximum month flow over the past 4-years. Flow projections were
estimated using the formula provided in the Guidance for the Preparation of Engineering Reports and
Environmental Information Documents for Wastewater Treatment Plant Projects — May 2015.
Q2041 — QMax Month(current) + [(100 Cap da� x OP)] + QBerry Global(2041) + QFuture Indt2o41) + QFour Oaks(2041)
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Using the above referenced formula and the prior information detailed, the following table is a summary of
all the components and determination of the future 20-year flow. Due to the rapid growth of the region, an
assumption of a future industrial flow of 0.450 MGD is included in the projections below.
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Component
Flow (MGD)
QMax Month - Current
1.918
Population — Year 2021
4,122
Population — Year 2041
6,088
QBerry Global - Year 2041
0.750
QFuture Industry - Year 2041
0.450
QFour Oaks - Year 2041
0.442
Q2041
3.75
Based on the referenced guidance documents and the projection formula presented, the total estimated
future flow in year 20 of the planning period is 3.75-MGD, approximately twice the current permitted limit of
1.9-MGD. Therefore, per this justification of flow and demonstration of need, the following section evaluates
technologically feasible wastewater disposal options and their economic feasibility to meet this need.
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3.0 ENGINEERING ALTERNATIVE ANALYSIS
The Benson WWTP is in close proximity to the intersection of the 1-40 and 1-95 corridors. This location
potentially allows the Town to offer a regionalized approach to wastewater treatment for the area.
Expansion of the facility also offers the benefits of alleviating septage hauling capacity for surrounding areas
under heavy development. The Town seeks to be poised for future growth that has been witnessed in
nearby municipalities that have gained commitments from major corporations to establish substantial
presences. Furthermore, the Benson WWTP is close to the division between the Cape Fear and Neuse
River Basins. Potential discharge to Cape Fear basin would alleviate future interbasin transfer concerns.
However for purposes of this report, the alternatives evaluated are limited to those options that have the
clearest future impacts with established methods of predicting data. It should be noted that neighboring
municipalities are under the same time constraints to develop plans for future expansion and that
regionalization options will be closely monitored and investigated more thoroughly if reliable data indicates
this is a feasible option for the region.
As required by the NPDES Permit Unit, the following alternatives are evaluated to provide the most cost-
effective solution for disposal of the wastewater generated from the Town of Benson's service area.
Appendix C contains supporting information for the alternatives detailed herein.
The following alternatives are evaluated below.
Alternative 1: Discharge to Neuse River Basin
Alternative 1A: Expanded Discharge to Hannah Creek
Alternative 1 B: Additional Discharge to Stone Creek
Alternative 1C: Additional Discharge to Neuse River
Alternative 2: Additional Discharge to Cape Fear River Basin
Alternative 2A: Additional Discharge to Mingo Swamp
Alternative 2B: Additional Discharge to Thorntons Creek
Alternative 2C: Additional Discharge to Cape Fear River
Alternative 3: Partial Diversion of Influent Flow to Harnett County
Alternative 4: Partial Diversion of Influent Flow to City of Dunn
Alternative 5: Land Application Discharge
3.1 PLANT EXPANSION TO 3.75 MGD PERMITTED CAPACITY (ALT. 1, 2, AND 5)
Alternatives 1, 2, and 5 include either expanded or new discharge locations and hold a common need for
expansion of the plant to accommodate the increased influent flow. Optimizing the performance of the
existing facilities is a required step in any plant upgrade and expansion scenario. However, shortcomings
Town of Benson - WWTP
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are noted in several areas, especially with respect to current equipment lifespan and the planned increase
in plant flows. For a treatment expansion to 3.75 mgd, improving the existing WWTP would not be sufficient
to meet anticipated nutrient limits at the increased flows. With the exception of the items being addressed
during the currently ongoing 2020 Headworks Improvements project, the reasons identified in a 2007 PER
(see Appendix E) which evaluated discharge alternatives for an expansion up to 3.0 mgd are still applicable
and identify deficient areas of the plant:
• The mechanical bar screen has reached the end of its effective service life.
• The grit chamber is worn out and undersized for the increased flows.
• The existing diversion box at the head of the plant is inadequate as it currently allows influent to
bypass grit removal and screening at high flows and go directly to the equalization basin.
• The Parshall flume is of insufficient size to measure the increased flows.
• The influent lift station is of insufficient capacity to handle the design peak flow.
Note: The above listed components are being addressed in a ASADRA project funded by the Division of Water
Infrastructure's CWSRF Program. All improvements are designed for a 3.75 mgd capacity.
• The splitter box to the oxidation ditches is undersized for the increased flows.
• The oxidation ditches have insufficient volume for the future flows.
• The aerator brushes are expected to be near the end of their effective life.
• More clarifier surface area is needed to handle the projected average design flow.
• The filter lift pumping station will need to be paralleled with a new pumping station to account for
the additional flows.
• Some sections of yard piping are insufficient to convey additional flows.
• The tertiary filters are not sufficient for additional flow or to be used for de -nitrification.
In addition to the above items identified in the 2007 PER, the following additional limitations reinforce the
need for a new wastewater plant to be constructed to treat anticipated influent to meet future nutrient permit
requirements.
• Previous flood events over the last ten years have damaged plant electrical systems. Repair or
replacement of most electrical controls is required as well as improvement of backup power supply.
• 5-stage Biological Nutrient Removal (BNR) is required to meet anticipated nutrient permit limits.
• The oxidation ditches have problematic mixing and lack effective DO control.
• The filters are near the end of their effective life with one filter suspected of damage to the obsolete
underdrains and loss of media.
• Chlorine dosing systems is at the end of its effective life and is not flow paced.
Exhibit 3 shows the conceptual layout of a new 3.75 mgd plant on the existing site.
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Engineering Alternative Analysis
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LEGEND
EXISTING STRUCTURE
NEW STRUCTURE - PHASE 1
PROPOSED STRUCTURE
DEMOLISHED STRUCTURE
120 North Boylan Avenue
Raleigh, NC 27603-1423
[phone]
thewootencom pa ny.com
License Number : F-0115
FUTURE \ ( FUTURE 1
RAS / WAS
PUMP STATION
CHEMICAL BLDG
CLARIFIER
No 1
DEWATERING BLDG
HEADWORKS / INFLUENT
PUMP STATION (PHASE 1)
CLARIFIER
No 2
TOWN OF BENSON
JOHNSTON COUNTY NORTH CAROLINA
BENSON WWTP EXPANSION
Exhibit 3
SITE PLAN
T:\Projects\Benson-2293\CO\_CADD\DrawingSets\BENSON SITE PLAN.dwg
DISC FILTER 1
O
DISC FILTER 2
UV
EFFLUENT
PUMP STATION
Designed By:
Drawn By:
PMD
Project No.:
2293-CO
DECEMBER 2021
Scale:
AS SHOWN
Sheet No.:
1

3.1.1 DESCRIPTION
The principal components for expansion of the facility to 3.75 mgd are described as follows:
1. Construction of two new biological nutrient removal (BNR) basins to treat an average daily flow of
3.75 mgd.
2. Construction of two new 90-foot diameter clarifiers, with associated splitter box to direct mixed
liquor flow from the BNR basins.
3. Construction of a new RAS/WAS pump station and associated piping.
4. Construction of two (2) new filters and UV disinfection system to meet future effluent limits.
5. Construction of new aerobic sludge digestion/holding tank.
6. Construction of a new solids dewatering facility.
7. Construction of a chemical storage and feed facility.
8. Provide new generator and transfer switch.
3.1.2 CONSTRUCTION COST OPINION
BNR Basins (Qty. 2)
Clarifiers (Qty. 2) w/ New Splitter Box
RAS/WAS Pump Station
Filters (Qty. 2)
UV Disinfection System
Aerobic Digester / Holding Tank
Solids Dewatering Facility
Chemical Storage and Feed Facility
New Generator & Transfer Switch
Site Work/Yard Piping/Misc Metals/HVAC/Plumbing/Electrical
Total Construction Cost
Contingencies (10%)
Project Administration (Design, CA/CO, Legal, Bond Counsel)
Total Project Cost
3.1.3 ANNUAL OPERATION AND MAINTENANCE COSTS
$ 5,800,000
1,600,000
1,800,000
1,500,000
1,200,000
3,000,000
3,000,000
500,000
500,000
11,100, 000
$ 30,000,000
3,000,000
2,300,000
$ 35,300,000
Labor $ 415,000
Laboratory Testing 50,000
Supplies 125,000
Maintenance and Repair 100,000
Annual Power Cost 230,000
Total Annual Operation and Maintenance Costs $ 920,000
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3.1.4 ECONOMIC ANALYSIS
A. Basic Considerations
1. Planning Periods, years = 20
2. Capital Cost of Project = $ 35,300,000
3. Annual Operation and Maintenance Costs = $ 920,000
4. EPA Discount Rate, percent = 1.500
B. Present Worth Analysis
1. Initial Project Cost = $ 35,300,000
2. Present Worth of Annual O&M Costs = $ 15,795,000
Net Present Worth = $ 51,095,000
3.2 ALTERNATIVE 1: DISCHARGE TO THE NEUSE RIVER BASIN
The three alternatives described below consider the discharge of wastewater treated at the Benson WWTP
to the Neuse River Basin through the existing discharge point at Hannah Creek or in combination with an
additional discharge point in the basin for the 1.85 mgd in excess of its current permitted flow. The Benson
WWTP currently discharges to the Neuse River Basin and is a member of the Neuse River Compliance
Association. Costs associated with new discharge points in the basin are significantly reduced if the existing
Hannah Creek discharge location is maintained and only the additional 1.85 mgd is required for the new
discharge location. For this reason, a new discharge in the basin for 3.75 mgd was not considered. Stone
Creek is evaluated below due to its proximity to the plant, and the Neuse River was evaluated to avoid
possible low flow streams in the vicinity.
3.3 ALTERNATIVE 1A: EXPANDED DISCHARGE TO HANNAH CREEK
This alternative considers the discharge of all wastewater treated at the Benson WWTP to the existing
discharge point specified in NPDES permit NC0020389. Hannah Creek has been previously identified as a
low flow receiving stream as well as nutrient sensitive waters, so this alternative does not have merit as a
viable option. Regardless, the USGS was contacted with a Low -Flow Request to confirm Hannah Creek
was still designated as a zero -flow stream. This alternative would be the most straight -forward option that
would not require pumping influent or effluent to another location.
The 2007 PER prepared by The Wooten Company outlined the issues surrounding the current discharge
point and noted that the Division of Water Resources (DWR, formerly Division of Water Quality (DWQ))
refused to issue speculative limits for the increased flow to Hannah Creek due to its impairment. At this
time, Hannah Creek still resides on the State's 303(d) list and is therefore not evaluated further.
While Hannah Creek's listing removes it from being a viable alternative for the purposes of this report, it is
noted that further modeling efforts and potential reclassification of the stream could affect the stream's
status as a viable candidate for future discharge increases.
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3.4 ALTERNATIVE 1B: ADDITIONAL DISCHARGE TO STONE CREEK
This alternative considers the discharge of wastewater treated at the Benson WWTP to the existing
discharge point at Hannah Creek and an additional discharge point at Stone Creek. Both points are located
within the Neuse River Basin. The USGS was contacted with a Low -Flow Request and confirmed that Stone
Creek is designated as a zero -flow stream. Cost data is provided below as a comparison to other
alternatives, although the discharge location is not a viable option.
3.4.1 DESCRIPTION
The principal components for this alternative in addition to the new plant described in Section 3.1 are
described as follows:
1. Construction of a new effluent pump station.
2. Construction of 36,000 LF of 20-inch forcemain and an outfall at Stone Creek.
3.4.2 CONSTRUCTION COST OPINION
New Effluent Pump Station and Forcemain
Contingencies (10%)
Project Administration (Design, CA/CO, Legal, Bond Counsel)
Total Construction Cost
3.4.3 ANNUAL OPERATION AND MAINTENANCE COSTS
$ 9,260,000
930,000
750,000
$ 10,940,000
Labor $ 10,000
Laboratory Testing 6,000
Supplies 1,000
Maintenance and Repair 10,000
Annual Power Cost 26,000
Total Annual Operation and Maintenance Costs $ 53,000
3.4.4 ECONOMIC ANALYSIS
A. Basic Considerations
1. Planning Periods, years = 20
2. Capital Cost of Project = $ 10,940,000
3. Annual Operation and Maintenance Costs = $ 53,000
4. EPA Discount Rate, percent = 1.500
B. Present Worth Analysis
1. Initial Project Cost = $ 10,940,000
2. Present Worth of Annual O&M Costs = $ 910,000
Net Present Worth = $ 11,850,000
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3.5 ALTERNATIVE 1C: ADDITIONAL DISCHARGE TO NEUSE RIVER
This alternative considers the discharge of wastewater treated at the Benson WWTP to the existing
discharge point at Hannah Creek and an additional discharge point at Neuse River. Both points are located
within the Neuse River Basin.
3.5.1 DESCRIPTION
The principal components for this alternative in addition to the new plant described in Section 3.1 are
described as follows:
1. Construction of a new effluent pump station.
2. Construction of 62,750 LF of 24-inch forcemain and an outfall at the Neuse River.
3.5.2 CONSTRUCTION COST OPINION
New Effluent Pump Station and Forcemain
Contingencies (10%)
Project Administration (Design, CA/CO, Legal, Bond Counsel)
Total Construction Cost
3.5.3 ANNUAL OPERATION AND MAINTENANCE COSTS
$ 16,650,000
1,670,000
1,150, 000
$ 19,470,000
Labor $ 10,000
Laboratory Testing 6,000
Supplies 1,000
Maintenance and Repair 10,000
Annual Power Cost 23,000
Total Annual Operation and Maintenance Costs $ 50,000
3.5.4 ECONOMIC ANALYSIS
A. Basic Considerations
1. Planning Periods, years = 20
2. Capital Cost of Project = $ 19470,000
3. Annual Operation and Maintenance Costs = $ 50,000
4. EPA Discount Rate, percent = 1.500
B. Present Worth Analysis
1. Initial Project Cost = $ 19,470,000
2. Present Worth of Annual O&M Costs = $ 858,000
Net Present Worth = $ 20,328,000
Town of Benson - WWTP
Engineering Alternative Analysis
December 2021
14
XX

3.6 ALTERNATIVE 2: ADDITIONAL DISCHARGE TO THE CAPE FEAR RIVER BASIN
The three alternatives described below consider the discharge of wastewater treated at the Benson WWTP
to the existing discharge point at Hannah Creek of 1.9 mgd and an additional discharge point in the Cape
Fear River Basin for the 1.85 mgd in excess of its current permitted flow. There are advantages with caveats
associated with splitting flow between the two river basins. While the Benson WWTP currently discharges
to the Neuse River Basin and is a member of the Neuse River Compliance Association, the plant is in close
proximity to the Cape Fear River Basin. Similar to additional discharge locations in the Neuse River Basin,
costs associated with new discharge points in the Cape Fear River Basin are significantly reduced if the
existing discharge location is maintained and only the additional 1.85 mgd is required for the new discharge
location. For this reason, a new discharge in the Cape Fear River Basin for 3.75 mgd was not considered.
In addition to proximity to the Cape Fear River Basin, the Town of Benson would offset potential future
complications associated with an Interbasin Transfer by establishing a discharge point within the basin.
However, several streams near the plant are classified as swamp and cannot be viable alternatives.
"This supplementary classification allows the water to exceed the normal freshwater criteria
for dissolved oxygen and pH because of the natural conditions found in swamp waters.
The Division does not currently have a method for evaluating these criteria for new and
expanding discharges in swamp waters so a new discharge to [a stream classified as
swamp] is not possible at this time." — David Hill, DWR (see email in Appendix D)
Mingo Swamp is evaluated below due to its proximity and flows that exceed other alternatives, including
the current discharge point at Hannah Creek. However additional streams in the Cape Fear Basin were not
evaluated due to their classification. These streams included Stony Run, Juniper Creek, and Black River,
which are all closer to Benson WWTP than some alternatives evaluated below.
Furthermore, DWR is developing a nutrient control strategy for the Middle Cape Fear. DWR has also
indicated that new discharges in the Middle Cape Fear would not be considered until the current modeling
study that supports the nutrient control strategy is complete, which would be at least a year (see emails in
Appendix D).
3.7 ALTERNATIVE 2A: ADDITIONAL DISCHARGE TO MINGO SWAMP
This alternative considers the discharge of wastewater treated at the Benson WWTP to the existing
discharge point at Hannah Creek and an additional discharge point at Mingo Swamp.
3.7.1 DESCRIPTION
The principal components for this alternative in addition to the new plant described in Section 3.1 are
described as follows:
1. Construction of a new effluent pump station.
2. Construction of 24,500 LF of 20-inch forcemain and an outfall at the Mingo Swamp.
Town of Benson - WWTP
Engineering Alternative Analysis
December 2021
15
XX

3.7.2 CONSTRUCTION COST OPINION
New Effluent Pump Station and Forcemain
Contingencies (10%)
Project Administration (Design, CA/CO, Legal, Bond Counsel)
Total Construction Cost
3.7.3 ANNUAL OPERATION AND MAINTENANCE COSTS
$ 7,160,000
720,000
600,000
$ 8,480,000
Labor $ 10,000
Laboratory Testing 6,000
Supplies 1,000
Maintenance and Repair 10,000
Annual Power Cost 37,000
Total Annual Operation and Maintenance Costs $ 64,000
3.7.4 ECONOMIC ANALYSIS
A. Basic Considerations
1. Planning Periods, years = 20
2. Capital Cost of Project = $ 8,480,000
3. Annual Operation and Maintenance Costs = $ 64,000
4. EPA Discount Rate, percent = 1.500
B. Present Worth Analysis
1. Initial Project Cost
2. Present Worth of Annual O&M Costs
Net Present Worth
$ 8,480,000
$ 1,099,000
$ 9,579,000
3.8 ALTERNATIVE 2B: ADDITIONAL DISCHARGE TO THORNTONS CREEK
This alternative considers the discharge of wastewater treated at the Benson WWTP to the existing
discharge point at Hannah Creek and an additional discharge point at Thorntons Creek.
3.8.1 DESCRIPTION
The principal components for this alternative in addition to the new plant described in Section 3.1 are
described as follows:
1. Construction of a new effluent pump station.
2. Construction of 59,300 LF of 24-inch forcemain and an outfall at Thorntons Creek.
Town of Benson - WWTP
Engineering Alternative Analysis
December 2021
16
XX

3.8.2 CONSTRUCTION COST OPINION
New Effluent Pump Station and Forcemain
Contingencies (10%)
Project Administration (Design, CA/CO, Legal, Bond Counsel)
Total Construction Cost
3.8.3 ANNUAL OPERATION AND MAINTENANCE COSTS
$ 17,450,000
1,750,000
1,250,000
$ 20,450,000
Labor $ 10,000
Laboratory Testing 6,000
Supplies 1,000
Maintenance and Repair 10,000
Annual Power Cost 37,000
Total Annual Operation and Maintenance Costs $ 64,000
3.8.4 ECONOMIC ANALYSIS
A. Basic Considerations
1. Planning Periods, years = 20
2. Capital Cost of Project = $ 20,450,000
3. Annual Operation and Maintenance Costs = $ 64,000
4. EPA Discount Rate, percent = 1.500
B. Present Worth Analysis
1. Initial Project Cost
2. Present Worth of Annual O&M Costs
Net Present Worth
$ 20,450,000
$ 1,099,000
$ 21,549,000
3.9 ALTERNATIVE 2C: ADDITIONAL DISCHARGE TO CAPE FEAR RIVER
This alternative considers the discharge of wastewater treated at the Benson WWTP to the existing
discharge point at Hannah Creek and an additional discharge point at the Cape Fear River.
3.9.1 DESCRIPTION
The principal components for this alternative in addition to the new plant described in Section 3.1 are
described as follows:
1. Construction of a new effluent pump station.
2. Construction of 74,600 LF of 24-inch forcemain and an outfall at the Cape Fear River.
Town of Benson - WWTP
Engineering Alternative Analysis
December 2021
17
XX

3.9.2 CONSTRUCTION COST OPINION
New Effluent Pump Station and Forcemain
Contingencies (10%)
Project Administration (Design, CA/CO, Legal, Bond Counsel)
Total Construction Cost
3.9.3 ANNUAL OPERATION AND MAINTENANCE COSTS
$ 21,090,000
2,110,000
1,400,000
$ 24,600,000
Labor $ 10,000
Laboratory Testing 6,000
Supplies 1,000
Maintenance and Repair 10,000
Annual Power Cost 37,000
Total Annual Operation and Maintenance Costs $ 64,000
3.9.4 ECONOMIC ANALYSIS
A. Basic Considerations
1. Planning Periods, years = 20
2. Capital Cost of Project = $ 24,600,000
3. Annual Operation and Maintenance Costs = $ 64,000
4. EPA Discount Rate, percent = 1.500
B. Present Worth Analysis
1. Initial Project Cost = $ 24,600,000
2. Present Worth of Annual O&M Costs = $ 1,099,000
Net Present Worth = $ 25,699,000
3.10 ALTERNATIVE 3: DIVERSION OF INFLUENT FLOW TO HARNETT COUNTY
This alternative would maintain the WWTP at 1.9 mgd and would divert approximately 1.85 mgd of influent
to the Harnett County System. The 2020 Headworks Improvements project will satisfy necessary
improvements to the headworks facility for the screening of the pumped influent. As identified in the 2007
PER, approximately 59,400 LF of forcemain would need to be constructed to transport the flows to a
connection point with the Harnett County System. This distance exceeds the forcemain lengths of three of
the five discharge options described above and was not evaluated further due to uncertainty of Harnett
County capacity and capital costs related to treatment expansion at the Harnett County WWTP.
3.11 ALTERNATIVE 4: DIVERSION OF INFLUENT FLOW TO CITY OF DUNN
This alternative would maintain the WWTP at 1.9 mgd and would divert approximately 1.85 mgd of influent
to the City of Dunn System. While the 2020 Headworks Improvements project would satisfy necessary
improvements to the headworks facility for the screening of the pumped influent, the City of Dunn is currently
Town of Benson - WWTP
Engineering Alternative Analysis
December 2021
18
XX

undergoing the process of determining alternatives to expand their treatment capacity and therefore does
not have capacity to receive additional flow. Regionalization options are identified as future possibilities,
but this alternative is not a viable option for the near future and cannot be evaluated further for purposes of
this report.
3.12 ALTERNATIVE 5: LAND APPLICATION
This alternative considers disposal of the treated wastewater effluent in excess of 1.9 mgd by land
application. Rapid growth in the area has yielded land values increasing at alarming rates and the Town
has previously been unsuccessful in identifying commercial/industrial users that could make use of treated
effluent for uses such as irrigation of athletic fields, golf courses, etc. in the service area. Due to the lack of
demand for irrigation and uncertainty in a volatile real estate market, this alternative was not investigated
further.
Town of Benson - WWTP
Engineering Alternative Analysis
December 2021
19
XX

4.0 SELECTION OF ALTERNATIVE
The present worth cost analysis of the viable alternatives evaluated in Section 3.0 is summarized in the
below table.
E 5 — SUMMARY OF PRESENT WORTH COST-ANALYSIS-7OR
ATTERNATIVES
ECONOMIC PARAMETERS
ALT. 1B
Stone Creek
Discharge
ALT. 1C
Neuse River
Discharge
ALT. 2A
Mingo
Swamp
Discharge
ALT. 2B
Thorntons
Creek
Discharge
ALT. 2C
Cape Fear
Discharge
1. Capital Cost of Plant Project
$ 35,300,000
$ 35,300,000
$ 35,300,000
$ 35,300,000
$ 35,300,000
2. Present Worth of Annual O&M Costs
15,795,000
15,795,000
15,795,000
15,795,000
15,795,000
3. Net Present Worth Plant
$ 51,095,000
$ 51,095,000
$ 51,095,000
$ 51,095,000
$ 51,095,000
4. Capital Cost of Effluent Project
$ 10,940,000
$ 19,470,000
$ 8,848,000
$ 20,450,000
$ 24,600,000
5. Present Worth of Annual O&M Costs
910,000
858,000
1,099,000
1,099,000
1,099,000
6. Net Present Worth Effluent Project
$ 11,850,000
$ 20,328,000
$ 9,579,000
$ 21,549,000
$ 25,699,000
7. Net Present Worth Costs Total
$ 62,945,000
$ 71,423,000
$ 60,674,000
$ 72,644,000
$ 76,794,000
Considering the above present worth cost analysis, Alternative 2A which considers discharge of treated
effluent to the Mingo Swamp in the Cape Fear River basin provides the most cost-effective solution for
disposal of treated wastewater generated from the Benson WWTP. However, due to ongoing modeling
study in support of development of a nutrient control strategy for the Middle Cape Fear, Alternatives 2A,
2B, and 2C are eliminated from consideration at this time. Furthermore, low flows in Stone Creek eliminate
Alternative 1 B from consideration. Therefore, the findings of this Engineering Alternative Analysis identify
direct discharge to the Neuse River as the only viable option for the Town of Benson to expand treatment
capacity of the Benson WWTP. It is recommended that this report be provided as supporting documentation
for the NPDES major permit modification application for discharge of 3.75 MGD of treated effluent to the
Neuse River Basin via two discharge locations (Hannah Creek and Neuse River).
The Town has been appropriated $22,733,700 in the NC State Budget (S.L. 2021-180) for the expansion
of the WWTP to meet the future demands of the Town. The Town should continue to pursue additional
State and Federal funding in the upcoming funding cycles to overcome the estimated deficit in funds for the
design and construction of the expanded facility. Per the findings of this engineering evaluation, the only
viable option is expansion of the facility to 3.75 MGD and an additional discharge to the Neuse River.
Town of Benson - WWTP
Engineering Alternative Analysis
December 2021
20
XX

Considering the State appropriated funds, the estimated cost deficit for implementation of this alternative is
$32,036,300.
As described in this report, modeling of streams in the Cape Fear River Basin should be closely monitored
and investigated if discharge to the basin becomes a viable option. The following table indicates the average
flows obtained from the low flow requests sent to USGS. Mingo Swamp has the highest average flows of
the alternatives investigated and is also the most appealing alternative based on net present worth.
TABLE 6 — USGS RESPONSES TO LOW FLOW REQUESTS
POTENTIAL DISCHARGE LOCATIONS
Annual
7Q10
(Avg cfs)
Annual
30Q2
(Avg cfs)
A. Mingo Swamp at US 301
0.02
0.53
B. Hannah Creek, current discharge
0.018
0.48
C. Juniper Creek at US 421
0.0032
0.15
D. Stone Creek at Adams Road
0.0018
0.046
E. Thorntons Creek at NC-27
0.0018
0.085
In addition to closely monitoring the modeling and nutrient control strategy development in the Cape Fear
Basin to potentially revisit more appealing discharge options, the following recommendations are made for
the Town of Benson to pursue:
1. The Town should continue to work with the TMDL unit of DWR to monitor dissolved oxygen
(DO) levels in Hannah Creek. If the data shows that DO levels increase so that the values are
computed to be above the impairment level, the Town should work with the TMDL unit to de -
list Hannah Creek. (Note: In North Carolina, DO impairment in Class 'C' waters is triggered
when >_10.1 % of the samples are less than 4 mg/L.) If Hannah Creek were de -listed, the Town
would be able to pursue Alternative 1A as described in this report.
2. The Town should continue to be open to potential regional partners for the transport and/or
treatment of the Town's wastewater. If a partner can be found and favorable financing terms
can be arranged, the Town could pursue alternatives similar to Alternative 3 and Alternative 4
from this report.
3. The Town should continue to explore water reuse in the region and be ever -aware of potential
industries or other entities that might serve as significant reuse consumers.
Town of Benson - WWTP
Engineering Alternative Analysis
December 2021
21
XX

APPENDIX A

DocuSign Envelope ID: D57B5FFD-136C-4BC7-9A1C-5788CF31DC0D
ROY COOPER
Governor
DIONNE DELLI-GATTI
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
April 12, 2021
Mr. Frederick D. Nelson, Town Manager
Town of Benson
303 E. Church Street
Benson, North Carolina 27504
Subject: Final NPDES Permit Renewal
Permit NC0020389
Benson WWTP
Johnston County
Grade IV Biological WPCS
SIC Code 4952
Dear Mr. Nelson:
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007
(or as subsequently amended).
Please note that the receiving stream is listed as impaired for dissolved oxygen on the North
Carolina 2018 303(d) Impaired Waters List. Addressing impaired waters is a high priority with
the Division, and instream data will continue to be evaluated. If there is noncompliance with
permitted effluent limits and stream impairment can be attributed to your facility, then mitigative
measures may be required.
The following changes were made to the draft permit sent to you on January 26, 2021:
• The expiration date was modified to more closely fit a 5-year permit cycle. Accordingly,
the specified years for the Effluent Pollutant Scans have been modified (2023, 2024,
2025). See Special Condition A. (7.).
The final permit maintains the following significant changes identified in the letter sent on
January 26, 2021:
• A notation was made concerning the Electronic Reporting Rule — Phase 2 Extension.
extended the Phase 2 deadline from December 21, 2020, to December 21, 2025, effective
January 4, 2021. The current compliance date has been extended to reflect this change [See
A. (8.)].
• Based on NPDES guidance regarding the reduction of monitoring frequencies in NPDES
permits for exceptionally performing facilities, monitoring requirements for
NORT£ D E
Department of Environmental Quality/
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

DocuSign Envelope ID: D57B5FFD-136C-4BC7-9A1C-5788CF31DCOD
BOD5 (winter), NH3-N (winter), Total Suspended Solids and Fecal Coliform have been
reduced to twice per week [See A. (1)].
• As the chemical feed systems for alum/lime are no longer in use, it has been removed from
the facility components list on the Supplement to Cover Sheet.
• Based on the reasonable potential analysis (RPA) showing no reasonable potential to
violate state water quality standards, the monitoring requirements for copper and zinc have
been removed from the permit [See A. (1)].
• Based on the reasonable potential analysis (RPA) showing reasonable potential to violate
state water quality standards, total nickel limits have been added to the permit and the
quarterly monitoring requirement has been changed to monthly monitoring [See A.(1)].
• The NC 2007-2014 Water Quality Standard (WQS) Triennial Review was approved by the
NC Environmental Management Committee (EMC) on November 13, 2014. The US EPA
subsequently approved the WQS revisions on April 6, 2016 with some exceptions. The NC
Division of Water Resources NPDES Permitting Unit is required to implement the new
dissolved metal standards in all permits public noticed after April 6, 2016. The new
standards for most metals include acute standards. Further, the freshwater standards for
several metals are expressed as the dissolved form of the metals, and seven metals have
hardness -dependent equations. As a result, the NPDES Permitting Unit will need site -
specific effluent hardness data and instream hardness data, upstream of the discharge, for
each facility monitoring these metals in order to calculate permit limitations. Effluent
hardness and instream hardness sampling, upstream of the discharge, have been added to
the permit at a monitoring frequency of quarterly [See A. (1.)].
• The Town's allowable discharge concentrations are 0.931 µg/L, 5.786 µg/L, 5.0 µg/L, and
0.06 µg/L for Cadmium, Lead, Selenium, and Silver, respectively. DWR's laboratory
identifies the target Practical Quantification Limits (PQLs) for Cadmium, Lead, Selenium,
and Silver as 0.5 µg/L, 2.0 µg/L, 1.0 µg/L and 1.0 µg/L, respectively. 15A NCAC 2B .0505
(e) (4) requires that all test procedures must produce detection and reporting levels that are
below the permit discharge requirements and all data generated must be reported to the
approved detection level or lower reporting level of the procedure. If no approved methods
are capable of achieving a detection level below the permit discharge requirement (or
allowable discharge concentration) the method with the lowest detection level must be
used. The Town should continue to use sufficiently sensitive test methods for all pollutants,
including when performing Effluent Pollutant Scans.
• Some of the wording has changed in Special Condition A. (2.), Chronic Toxicity Permit
Limit, please review each paragraph carefully.
• Special Condition A. (7.) has been modified to include the specific three years in which
the Effluent Pollutant Scan shall be performed. In addition, at the end of the Special
Condition, 2nd species Toxicity Testing Requirements for municipal permit renewals per
Federal Regulations [40 CFR 122.21(j)(5)] have been added.
• Federal regulations require electronic submittal of all discharge monitoring reports
(DMRs) and program reports. The requirement to continue reporting discharge monitoring
data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR)
internet application has been added to your NPDES permit [See Special Condition A. (8.)].
• A notation was made concerning the Electronic Reporting Rule — NPDES Electronic
Reporting Rule — Phase 2 Extension. EPA extended the Phase 2 deadline to December 21,
2025. The current compliance date, effective January 4, 2021, was extended as a final
regulation change published in the November 2, 2020 Federal Register. [See A. (8.)]
Page 2 of 3

DocuSign Envelope ID: D57B5FFD-136C-4BC7-9A1C-5788CF31DCOD
• Parameter codes have been added to the Effluent Limitations and Monitoring Requirements
[ See A. (1.)].
• Regulatory citations have been added to the permit.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within
thirty (30) days following receipt of this letter. This request must be in the form of a written
petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the
Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-
6714). Unless such demand is made, this decision shall be final and binding.
The NPDES standard conditions (Parts II, III, and IV) are the same as in your current permit
except that agency and division names have been updated. The latest version is available at
https://bit.ly/3k5NFaL and can be viewed online or downloaded as a PDF file.
Please note that this permit is not transferable except after notice to the Division. The Division
may require modification or revocation and reissuance of the permit. This permit does not affect
the legal requirements to obtain other permits which may be required by the Division of Water
Resources or any other Federal, State, or Local governmental regulations.
If you have any questions concerning this permit, please contact Cassidy Kurtz at [phone]
or via email at [e-mail].
Sincerely,
Do'c'u.Ltt
y1
Si-gned by:hitt4 AA tliAA
C464531431644FE...
for S. Daniel Smith, Director
Division of Water Resources, NCDEQ
Hardcopy: NPDES Files
Central Files
Ecopy: US EPA Region 4
DWR/Raleigh Regional Office/Water Quality
DWR/Ecosystems Branch/Mark Vander Borgh
DWR/Aquatic Toxicology Branch/Cindy Moore and Zach Thomas
DWR/Municipal Unit — Pretreatment/Kristin Litzenberger
Benson WWTP/Brian Leavitt, ORC
Town of Benson/Tim Robbins, Public Utilities Director
Page 3 of 3

DocuSign Envelope ID: D57B5FFD-136C-4BC7-9A1C-5788CF31DCOD
Permit NC0020389
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Water Quality Commission, and the Federal Water
Pollution Control Act, as amended, the
Town of Benson
is hereby authorized to discharge wastewater from a facility located at the
Benson Wastewater Treatment Facility
770 Hannah Creek Road (south of I-95)
Four Oaks
Johnston County
to receiving waters designated as Hannah Creek in the Neuse River Basin
in accordance with the discharge limitations, monitoring requirements, and other conditions set forth in Parts I, II,
III and IV hereof.
This permit shall become effective: May 1, 2021.
This permit and authorization to discharge shall expire at midnight on April 30, 2026.
Signed this day: April 12, 2021.
DocuSigned by:
C464531431644FE...
for S. Daniel Smith, Director
Division of Water Resources
By Authority of the Environmental Management Commission

DocuSign Envelope ID: D57B5FFD-136C-4BC7-9A1C-5788CF31DCOD
Permit NC0020389
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this
permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive
authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and
provisions included herein.
The Town of Benson
is hereby authorized to:
1. Continue to operate an existing 1.9 MGD wastewater treatment facility, located at the Benson WWTP off
Hannah Creek Road in Four Oaks in Johnston County, consisting of the following equipment:
• Bar screens
• Grit removal
• Parshall flume with flow measurement
• Influent composite sampler
• Influent screw pumps
• Three extended aeration/oxidation basins/nutrient reduction
• Five secondary clarifiers
• Tertiary filters
• Chlorine contact basin
• Dechlorination
• Post aeration
• Effluent flow measurement
• Effluent composite sampler
• Aerated sludge lagoon
• Two stabilization lagoon (also act as influent flow storage)
• Lagoon effluent return pump station
• Backup generator; and
2. Operate facilities for reuse water up to 0.02672 MGD in accordance with Non -Discharge permit WQ0022501;
and
3. Discharge wastewater from said treatment works at the location specified on the attached map into Hannah
Creek, classified C-NSW waters in the Neuse River Basin.
ii

DocuSign Envelope ID: D57B5FFD-136C-4BC7-9A1 C-5788CF31 DCOD
PART I
Permit NC0020389
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.] Grade IV Biological Water Pollution Control System
[15A NCAC 08G .0302]
Beginning on the effective date of this permit and lasting until expiration, the Permittee is
authorized to discharge treated wastewater from Outfall 001. Such discharges shall be limited and
monitored' by the Permittee as specified below:
PARAMETER CHARACTERISTICS
Parameter Code
EFFLUENT LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location 2
Flow
50050
1.9 MGD
Continuous
RecordingInfluent
or
Effluent
Total Monthly Flow (MG) 3
82220
Monitor and Report
Monthly
Recorded or
Calculated
Effluent
BOD 5-day, 20°C 4
(April 1 — October 31)
C0310
5.0 mg/L
7.5 mg/L
Daily
Composite
Influent &
Effluent
BOD5 day, 20°C
(November 1 — March 31)
4
C0310
10.0 mg/L
15.0 mg/L
2/week 14
Composite
Influent & Effluent
Total Suspended Solids
(TSS) 4
C0530
30.0 mg/L
g
45.0 mg/L
gEffluent
2/week 14
Composite
Influent &
Ammonia (NH3 as N)
(April 1 - October 31)
C0610
1.0 mg/L
3.0 mg/L
Daily
Composite
Effluent
Ammonia (NH3 as N)
(November 1 - March 31)
C0610
2.0 mg/L
6.0 mg/L
2/week 14
Composite
Effluent
pH
00400
Between 6.0 and 9.0 standard units
Daily
Grab
Effluent
Dissolved Oxygen (mg/L)
00300
Daily Average >_ 6.0 mg/L
Daily
Grab
Effluent
Fecal Coliform
(geometric mean)
31616
200/100 mL
400/100 mL
2/week 14
Grab
Effluent
Temperature (°C)
00010
Monitor and Report
Daily
Grab
Effluent
Conductivity (mohms/cm)
00094
Monitor and Report
Daily
Grab
Effluent
Total Residual Chlorine
(TRC) 5
50060
17 /L
l�9
DailyGrab
Effluent
TKN (mg/L) 6
00625
Monitor and Report
Weekly
Composite
Effluent
NO3-N + NO2-N (mg/L) 6
00630
Monitor and Report
Weekly
Composite
Effluent
TN (mg/L) 3,6
C0600
Monitor and Report
Weekly
Composite
Effluent
TN Load 3
QM600
QY600
Monitor and Report (pounds/month)
Monthly
Calculated
Effluent
33,070 pounds/year (annual mass loading)
Annually
Calculated
Effluent
Total Phosphorus
C0665
2.0 mg/L (Quarterly Average)8
Weekly
Composite
Effluent
Total Nickel 9
01067
62.1 pg/L
558.9 pg/L
Monthly
Composite
Effluent
Chronic Toxicity 10
TGP3B
Monitor and Report
Quarterly
Composite
Effluent
Effluent Pollutant Scan
NC01
Monitor and Report
See Footnote 11
Effluent
Total Hardness [as
CaCO3] (mg/L)12
00900
Monitor and Report
p
QuarterlyComp
p osite
Effluent
Dissolved Oxygen (mg/L)
00300
Monitor and Report
Variable 2
Grab
U & D
Fecal Coliform (geometric
mean)
31616
Monitor and Report
Variable 2
Grab
U & D
Temperature (°C)
00010
Monitor and Report
Variable 2
Grab
U & D
Cont. on next page
Page 1 of 10

DocuSign Envelope ID: D57B5FFD-136C-4BC7-9A1C-5788CF31DCOD
Permit NC0020389
PARAMETER CHARACTERISTICS
Parameter Code
EFFLUENT LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location 2
Conductivity (mohms/cm) 00094
Monitor and Report
Variable 2
Grab
U & D
Total Hardness [as 00900
CaCO3] (mg/L)13
Monitor and Report
p
QuarterlyGrab
U & D
Footnotes:
1. Submit discharge monitoring reports electronically using the NC DWR's eDMR application system. See
section A. (8.).
2. U: Upstream at the culvert on NCSR 1158. D: Downstream at NCSR 1227. Stream samples shall be
grab samples collected 3/Week from June to September and 1/Week during the remaining months of the
year. As a participant in the Lower Neuse River Basin Association, the instream monitoring requirements
as stated above are waived. Should your membership in the association be terminated, you shall notify
the Division immediately and the instream monitoring requirements specified in your permit shall be
reinstated.
3. Total Nitrogen Load is the mass quantity of Total Nitrogen (TN) discharged in a given period of time and
requires Total Monthly Flow (TMF). See condition A. (3.). Calculation of Total Nitrogen Loads.
4. The monthly average effluent BODS and Total Suspended Residue concentrations shall not exceed 15%
of the respective influent value (85% removal).
5. Total Residual Chlorine compliance is required if chlorine or chlorine derivative is used for disinfection.
The Division shall consider all effluent TRC values reported below 50 ug/1 to be in compliance with the
permit. However, the Permittee shall continue to record and submit all values reported by a North
Carolina certified laboratory (including field certified), even if these values fall below 50 ug/1.
6. For a given wastewater sample, Total Nitrogen (TN) = TKN + (NO3-N + NO2-N) where TKN is Total
Kjeldahl Nitrogen, and (NO3-N + NO2-N) is Nitrate and Nitrite Nitrogen.
7. Compliance with this limit shall be determined in accordance with conditions A. (4.) Annual Limits for
Total Nitrogen. and A. (5.) Total Nitrogen Allocations.
8. The quarterly average for total phosphorus shall be the average of composite samples collected weekly
during the calendar quarter (January -March, April -June, July -September, October -December).
9. Monitoring for Nickel shall be conducted in conjunction with the Chronic Toxicity monitoring.
10. Chronic Toxicity (Ceriodaphnia dubia) P/F at 90%: January, April, July, and October [see
condition A. (2.)]. Toxicity monitoring shall coincide with metals monitoring.
11. The permittee shall perform three Effluent Pollutant Scans during the term of this permit [see A.
(7.)].
12. Effluent Total Hardness sampling shall be performed in conjunction with testing for hardness -
dependent metals (cadmium, copper, lead, nickel, silver, and zinc).
13. The permittee shall sample instream hardness upstream of the facility's discharge. The sample
shall be representative of the hardness in the receiving stream. If the permittee is a member of a
monitoring coalition program, sampling for instream hardness may be waived as long as the
monitoring coalition agrees to sample hardness at the nearest upstream location, at a minimum
frequency of quarterly, and the permittee has obtained approval from DWR-NPDES Permitting
Unit that the upstream station being monitored by the Coalition is representative of the receiving
stream for this discharge. The permittee is responsible for submitting instream hardness test
results with its permit renewal application package. If Coalition membership is cancelled or the
Coalition terminates instream hardness sampling at the approved station, the permittee will
immediately notify the Division and resume sampling for instream hardness upstream of its
discharge.
14. 2/week sampling must occur on any two non-consecutive days during the calendar week.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
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DocuSign Envelope ID: D57B5FFD-136C-4BC7-9A1C-5788CF31DCOD
Permit NC0020389
A. (2.) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
[15A NCAC 02B .0200 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 90%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or subsequent versions
or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised- December 2010) or
subsequent versions. The tests will be performed during the months of January, April, July, and October.
These months signify the first month of each three-month toxicity testing quarter assigned to the facility. Effluent
sampling for this testing must be obtained during representative effluent discharge and shall be performed at the
NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the
permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two
following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised -December 2010) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered electronically using the
Division's eDMR system for the months in which tests were performed, using the parameter code TGP3B for the
pass/fail results and THP3B for the Chronic Value. Additionally, DWR Form AT-3 (original) is to be sent to the
following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Or, results can be sent to the email, ATForms.ATB(aincdenr.gov.
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30 days after
the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the Permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the
facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No
Flow" in the comment area of the form. The report shall be submitted to the Water Sciences Section at the address
cited above.
Should the Permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month. Assessment of toxicity compliance is based on the toxicity testing quarter,
which is the three month time interval that begins on the first day of the month in which toxicity testing is
required by this permit and continues until the final day of the third month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water
Resources indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
include alternate monitoring requirements or limits.
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DocuSign Envelope ID: D57B5FFD-136C-4BC7-9A1C-5788CF31DCOD
Permit NC0020389
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.
A. (3.) CALCULATION OF TOTAL NITROGEN LOADS
[G.S. 143-215.1(b)]
a. The Permittee shall calculate monthly and annual TN Loads as follows:
1.Monthly TN Load (pounds/month) = TN x TMF x 8.34
where: TN = the average Total Nitrogen concentration (mg/L) of the composite samples
collected during the month
TMF = the Total Monthly Flow of wastewater discharged during the month
(MG/month)
8.34 = conversion factor, from (mg/L x MG) to pounds
2.Annual TN Load (pounds/year) = Sum of the 12 Monthly TN Loads for the calendar year
b. The Permittee shall report monthly Total Nitrogen results (mg/L and pounds/month) in the appropriate
discharge monitoring report for each month and shall report each year's results (pounds/year) with the
December report for that year.
A. (4.) ANNUAL LIMITS FOR TOTAL NITROGEN
[G.S. 143-215.1(b)]
a. Total Nitrogen (TN) allocations and TN Load limits for NPDES dischargers in the Neuse River
basin apply on a calendar year basis.
b. For any given calendar year, the Permittee shall be in compliance with the annual TN Load limit in this
Permit if:
(i.) the Permittee's annual TN discharge is less than or equal to its TN Load limit, or
(ii.) the Permittee is a co-permittee member of a compliance association.
c. If the Permittee is not a co-permittee member of a compliance association and the Permittee's cumulative
annual TN discharge exceeds the effective TN Load limit in this permit at any point during the calendar
year, the Permittee is in violation of its TN Load limit, and each day of a continuing violation shall
constitute a separate violation.
d. The TN Load limit in this Permit (if any) may be modified as the result of allowable changes in the
Permittee's TN allocation.
(iii.) Allowable changes include those resulting from purchase of TN allocation from the Wetlands
Restoration Fund; purchase, sale, trade, or lease of allocation between the Permittee and other
dischargers; regionalization; and other transactions approved by the Division.
(iv.) The Permittee may request a modification of the TN Load limit in this Permit to reflect allowable
changes in its TN allocation. Upon receipt of timely and proper application, the Division will modify
the permit as appropriate and in accordance with state and federal program requirements.
(v.) Changes in TN limits become effective on January 1 of the year following permit modification. The
Division must receive application no later than August 31 for changes proposed for the following
calendar year.
(vi.) Application shall be sent to:
NCDWR / NPDES Programs
Attn: Neuse River Basin Coordinator
1617 Mail Service Center
Raleigh, NC 27699-1617
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DocuSign Envelope ID: D57B5FFD-136C-4BC7-9A1C-5788CF31DCOD
Permit NC0020389
e. If the Permittee is a member and co-permittee of an approved compliance association, its TN discharge
during that year is governed by that association's group NPDES permit and the TN limits therein.
(vii.) The Permittee shall be considered a Co-Permittee Member for any given calendar year in which it is
identified as such in Appendix A of the association's group NPDES permit.
(viii.) Association roster(s) and members' TN allocations will be updated annually and in accordance with
state and federal program requirements.
(ix.) If the Permittee intends to join or leave a compliance association, the Division must be notified of the
proposed action in accordance with the procedures defined in the association's NPDES permit.
(A) Upon receipt of timely and proper notification, the Division will modify the permit as
appropriate and in accordance with state and federal program requirements.
(B) Membership changes in a compliance association become effective on January 1 of the year
following modification of the association's permit.
f. The TN monitoring and reporting requirements in this Permit remain in effect until expiration of this Permit
and are not affected by the Permittee's membership in a compliance association.
A. (5.) TOTAL NITROGEN ALLOCATIONS
[15A NCAC 02B .0713]
The following table lists the Total Nitrogen (TN) allocation(s) assigned to, acquired by, or transferred to
the Permittee in accordance with the Neuse River nutrient management rule (T15A NCAC 02B .0713)
and the status of each as of permit issuance. These allocations and credits are not enforceable limits nor
do they supersede any TN limit(s) established elsewhere in this permit or in the NPDES permit of a
compliance association of which the permittee is a Co-permittee Member.
ALLOCATION
TYPE
SOURCE
DATE
ALLOCATION AMOUNT'
STATUS
Estuary
(lb/year)
Discharge
(lb/year)
Base
Assigned by Rule
(T15A NCAC 02B .0713)
12/7/97;
4/1/03;
1/1/2019
16,895
33,790
Active
Decremental
Sale to Central Johnston
County NC0030716
4/2/08
360
720
Deducted
TOTAL
16,535
33,070
Active
Footnote:
1. Transport Factor = 50%
Any addition, deletion, or modification of the listed allocation(s) (other than to correct typographical errors)
or any change to Active status of any of the listed allocations shall be considered a major modification of
this permit and shall be subject to the public review process afforded such modifications under state and
federal rules.
A. (6.) LAGOON FREEBOARD HEIGHT REQUIREMENT
[40 CFR 122.41 (e)]
A minimum of 2 feet of freeboard height must be maintained in the lagoons (currently used for
equalization/sludge holding). A staff gauge must be placed in each lagoon and the height recorded daily.
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DocuSign Envelope ID: D57B5FFD-136C-4BC7-9A1C-5788CF31DCOD
Permit NC0020389
A. (7.) EFFLUENT POLLUTANT SCAN (Municipal POTWs)
[G.S. 143-215.1(b)]
a. The Permittee shall perform a total of three (3) Effluent Pollutant Scans for all parameters listed below.
One scan must be performed in each of the following years: 2023, 2024, and 2025. Analytical methods
shall be in accordance with 40 CFR Part 136 and shall be sufficiently sensitive to determine whether
parameters are present in concentrations greater than applicable standards and criteria. Samples should be
collected with one quarterly toxicity test each year, and must represent seasonal variation [i.e., do not
sample in the same quarter every year]. Unless otherwise indicated, metals shall be analyzed as "total
recoverable."
Ammonia (as N)
Chlorine (total residual, TRC)
Dissolved oxygen
Nitrate / Nitrite
Kjeldahl nitrogen
Oil and grease
Phosphorus
Total dissolved solids
Hardness
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury (Method 1631E)
Nickel
Selenium
Silver
Thallium
Zinc
Cyanide
Total phenolic compounds
Volatile organic compounds:
Acrolein
Acrylonitrile
Benzene
Bromoform
Carbon tetrachloride
Chlorobenzene
Chlorodibromomethane
Chloroethane
2-chloroethyl vinyl ether
Chloroform
Dichlorobromomethane
1,1-dichloroethane
1,2-dichloroethane
C0610
50060
00300
00630
00625
00556
C0665
70295
00900
01097
01002
01012
01027
C0034
01042
01051
COMER
01067
01147
01077
01059
01092
00720
32730
34210
34215
34030
32104
32102
34301
34306
85811
34576
32106
32101
34496
32103
Trans-1,2-dichloroethylene
1,1-dichloroethylene
1,2-dichloropropane
1,3-dichloropropylene
Ethylbenzene
Methyl bromide
Methyl chloride
Methylene chloride
1,1,2,2-tetrachloroethane
Tetrachloroethylene
Toluene
1,1,1-trichloroethane
1,1,2-trichloroethane
Trichloroethylene
Vinyl chloride
Acid -extractable compounds:
P-chloro-m-cresol
2-chlorophenol
2,4-dichlorophenol
2,4-dimethylphenol
4,6-dinitro-o-cresol
2,4-dinitrophenol
2-nitrophenol
4-nitrophenol
Pentachlorophenol
Phenol
2,4,6-trichlorophenol
Base -neutral compounds:
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo(a)anthracene
Benzo(a)pyrene
3,4 benzofluoranthene
Benzo(ghi)perylene
Benzo(k)fluoranthene
Bis (2-chloroethoxy) methane
34546
34501
C0541
77163
34371
34413
34418
34423
81549
34475
34010
34506
34511
39180
39175
34452
34586
34601
34606
34657
34616
34591
34646
39032
34694
34621
34205
34200
CO220
39120
C0526
34247
34230
34521
34242
34278
Bis (2-chloroethyl) ether
Bis (2-chloroisopropyl) ether
Bis (2-ethylhexyl) phthalate
4-bromophenyl phenyl ether
Butyl benzyl phthalate
2-chloronaphthalene
4-chlorophenyl phenyl ether
Chrysene
Di-n-butyl phthalate
Di-n-octyl phthalate
Dibenzo(a,h)anthracene
1,2-dichlorobenzene
1,3-dichlorobenzene
1,4-dichlorobenzene
3,3-dichlorobenzidine
Diethyl phthalate
Dimethyl phthalate
2,4-dinitrotoluene
2,6-dinitrotoluene
1,2-diphenylhydrazine
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclo-pentadiene
Hexachloroethane
Indeno(1,2,3-cd)pyrene
Isophorone
Naphthalene
Nitrobenzene
N-nitrosodi-n-propylamine
N-nitrosodimethylamine
N-nitrosodiphenylamine
Phenanthrene
Pyrene
1,2,4-trichlorobenzene
34273
34283
C0100
34636
34292
34581
34641
34320
39110
34596
34556
34536
34566
34571
34631
34336
34341
34611
C0626
34346
C0376
34381
C0700
C0702
34386
34396
34403
34408
34696
34447
34428
34438
34433
34461
34469
C0551
1. Reporting. Test results shall be reported electronically using the Division's eDMR system
or on DWR Form DMR-PPA-1(or on a form approved by the Director) by December 31st of
each designated sampling year.
2. The Permittee must at least report completion of the test in the eDMR system by entering "1" or "Y"
for parameter code NC01 - Annual Pollutant Scan. If utilizing the DWR Form submit to the
following address:
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DocuSign Envelope ID: D57B5FFD-136C-4BC7-9A1C-5788CF31DCOD
Permit NC0020389
NC DEQ / DWR / NPDES Files, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617.
Or the form may be uploaded at: https://edocs.deq.nc.gov/Forms/NPDES WW-EDMR-Supplemental-
Form
b. Additional Toxicity Testing Requirements for Municipal Permit Renewal. Please note that
Municipal facilities that are subject to the Effluent Pollutant Scan requirements listed above are also
subject to additional toxicity testing requirements specified in Federal Regulation 40 CFR 122.21(j)(5).
The US EPA requires four (4) toxicity tests for a test organism other than the test species currently
required in this permit. The multiple species tests should be conducted either quarterly for a 12-month
period prior to submittal of the permit renewal application, or four tests performed at least annually in the
four and one half year period prior to the application. These tests shall be performed for acute or chronic
toxicity, whichever is specified in this permit. The multiple species toxicity test results shall be filed with
the Aquatic Toxicology Branch at the following address:
North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Or, results can be sent to the email, ATForms.ATB@a,ncdenr.gov.
Contact the Division's Aquatic Toxicology Branch at 919-743-8401 for guidance on conducting the
additional toxicity tests and reporting requirements. Results should also be summarized in Part E
(Toxicity Testing Data) of EPA Municipal Application Form 2A, when submitting the permit renewal
application to the NPDES Permitting Unit.
A. (8.) ELECTRONIC REPORTING - DISCHARGE MONITORING REPORTS
[G.S. 143-215.1 (b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports.
The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of this permit
(Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)1
The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and submitted
electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring data and
submit DMRs electronically using the internet. The eDMR system may be accessed at:
https:/ / deq.nc.gov/ about/ divisions/water-resources/ edmr.
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being
physically located in an area where less than 10 percent of the households have broadband access, then a
temporary waiver from the NPDES electronic reporting requirements may be granted and discharge
monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or alternative forms approved by
the Director. Duplicate signed copies shall be submitted to the following address:
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DocuSign Envelope ID: D57B5FFD-136C-4BC7-9A1C-5788CF31DCOD
Permit NC0020389
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
See "How to Request a Waiver from Electronic Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the month following the
issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
Starting on December 21, 2025, the permittee must electronically report the following compliance
monitoring data and reports, when applicable:
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
• Clean Water Act (CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request a Waiver
from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time of each
electronic submission. The permittee should use the EPA's website resources to identify the initial recipient
for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity (EPA or
the state authorized by EPA to implement the NPDES program) that is the designated entity for receiving
electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each type of
electronic submission and for each state. Instructions on how to access and use the appropriate electronic
reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting Rule is found at:
https://www.federalregister. gov/documents/2015/ 10/22/2015-24954/national-pollutant-discharge-elimination-
system-npdes-electronic-reporting-rule
Electronic submissions must start by the dates listed in the "Reporting Requirements" section above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an electronic
reporting waiver, a permittee must first submit an electronic reporting waiver request to the Division.
Requests for temporary electronic reporting waivers must be submitted in writing to the Division for written
approval at least sixty (60) days prior to the date the facility would be required under this permit to begin
submitting monitoring data and reports. The duration of a temporary waiver shall not exceed 5 years and
shall thereupon expire. At such time, monitoring data and reports shall be submitted electronically to the
Division unless the permittee re -applies for and is granted a new temporary electronic reporting waiver by the
Division. Approved electronic reporting waivers are not transferrable. Only permittees with an approved
reporting waiver request may submit monitoring data and reports on paper to the Division for the period that
the approved reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on the
following web page:
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DocuSign Envelope ID: D57B5FFD-136C-4BC7-9A1C-5788CF31DCOD
Permit NC0020389
http://deq.nc.gov/about/divisions/water-resources/edmr
4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)1
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II, Section
B. (11.)(a) or by a duly authorized representative of that person as described in Part II, Section B. (11.)(b). A
person, and not a position, must be delegated signatory authority for eDMR reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and
login credentials to access the eDMR system. For more information on North Carolina's eDMR system,
registering for eDMR and obtaining an eDMR user account, please visit the following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the
following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE
ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or
those persons directly responsible for gathering the information, the information submitted is, to the best of
my knowledge and belief true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fines and imprisonment for knowing violations."
5. Records Retention [Supplements Section D. (6.)1
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from the
date of the report. This period may be extended by request of the Director at any time [40 CFR
122.41].
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DocuSign Envelope ID: D57B5FFD-136C-4BC7-9A1 C-5788CF31 DCOD
Permit NC00203 89
JE S Glad: F24NE Benson. NC
Outfa:: FaciIcy
Latitude: 35° 39' 02' N 35° 23' 37.7' N
Longitude: 78° 50' 78' W 78° 30' 32.7' W
Stream Class: C. NSW
Subbasin: 03-04-04
Recevng Stream: Hannah Creek
Facility
Location
North
Town of Benson WWTP NC0020389
Johnston County
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DocuSign Envelope ID: D57B5FFD-136C-4BC7-9A1C-5788CF31DCOD
NPDES Permit Standard Conditions
Page 1 of 18
PART II
STANDARD CONDITIONS FOR NPDES PERMITS
Section A. Definitions
2/Month
Samples are collected twice per month with at least ten calendar days between sampling events. These samples shall be
representative of the wastewater discharged during the sample period.
3/Week
Samples are collected three times per week on three separate calendar days. These samples shall be representative of
the wastewater discharged during the sample period.
Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33 USC 1251, et.
seq.
Annual Average
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar year. In the case of fecal
coliform, the geometric mean of such discharges.
Arithmetic Mean
The summation of the individual values divided by the number of individual values.
Bypass
The known diversion of waste streams from any portion of a treatment facility including the collection system, which is
not a designed or established or operating mode for the facility.
Calendar Day
The period from midnight of one day until midnight of the next day. However, for purposes of this permit, any
consecutive 24-hour period that reasonably represents the calendar day may be used for sampling.
Calendar Week
The period from Sunday through the following Saturday.
Calendar Quarter
One of the following distinct periods: January through March, April through June, July through September, and
October through December.
Composite Sample
A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100 mL in
such a manner as to result in a total sample representative of the wastewater discharge during the sample period. The
Director may designate the most appropriate method (specific number and size of aliquots necessary, the time interval
between grab samples, etc.) on a case -by -case basis. Samples may be collected manually or automatically. Composite
samples may be obtained by the following methods:
(1) Continuous: a single, continuous sample collected over a 24-hour period proportional to the rate of flow.
(2) Constant time/variable volume: a series of grab samples collected at equal time intervals over a 24 hour period
of discharge and combined proportional to the rate of flow measured at the time of individual sample
collection, or
Variable time/constant volume: a series of grab samples of equal volume collected over a 24 hour period with
the time intervals between samples determined by a preset number of gallons passing the sampling point. Flow
measurement between sample intervals shall be determined by use of a flow recorder and totalizer, and the
preset gallon interval between sample collection fixed at no greater than 1/24 of the expected total daily flow at
the treatment system, or
(3)
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(4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at a
constant time interval. Use of this method requires prior approval by the Director. This method may only be
used in situations where effluent flow rates vary less than 15 percent. The following restrictions also apply:
➢ Influent and effluent grab samples shall be of equal size and of no less than 100 milliliters
➢ Influent samples shall not be collected more than once per hour.
➢ Permittees with wastewater treatment systems whose detention time < 24 hours shall collect effluent grab
samples at intervals of no greater than 20 minutes apart during any 24-hour period.
➢ Permittees with wastewater treatment systems whose detention time exceeds 24 hours shall collect effluent
grab samples at least every six hours; there must be a minimum of four samples during a 24-hour sampling
period.
Continuous flow measurement
Flow monitoring that occurs without interruption throughout the operating hours of the facility. Flow shall be
monitored continually except for the infrequent times when there may be no flow or for infrequent maintenance
activities on the flow device.
Daily Discharge
The discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the
calendar day for purposes of sampling. For pollutants measured in units of mass, the "daily discharge" is calculated as
the total mass of the pollutant discharged over the day. For pollutants expressed in other units of measurement, the
"daily discharge" is calculated as the average measurement of the pollutant over the day. (40 CFR 122.2; see also
"Composite Sample," above.)
Daily Maximum
The highest "daily discharge" during the calendar month.
Daily Sampling
Parameters requiring daily sampling shall be sampled 5 out of every 7 days per week unless otherwise specified in the
permit. Sampling shall be conducted on weekdays except where holidays or other disruptions of normal operations
prevent weekday sampling. If sampling is required for all seven days of the week for any permit parameter(s), that
requirement will be so noted on the Effluent Limitations and Monitoring Page(s).
DWR or "the Division"
The Division of Water Resources, Depailment of Environmental Quality.
Effluent
Wastewater discharged following all treatment processes from a water pollution control facility or other point source
whether treated or untreated.
EMC
The North Carolina Environmental Management Commission
EPA
The United States Environmental Protection Agency
Facility Closure
Cessation of all activities that require coverage under this NPDES permit. Completion of facility closure will allow this
permit to be rescinded.
Geometric Mean
The Nth root of the product of the individual values where N = the number of individual values. For purposes of
calculating the geometric mean, values of "0" (or "< [detection level]") shall be considered = 1.
Grab Sample
Individual samples of at least 100 mL collected over a period of time not exceeding 15 minutes. Grab samples can be
collected manually Grab samples must be representative of the discharge (or the receiving stream, for instream
samples).
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Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the CWA.
Instantaneous flow measurement
The flow measured during the minimum time required for the flow measuring device or method to produce a result in
that instance. To the extent practical, instantaneous flow measurements coincide with the collection of any grab
samples required for the same sampling period so that together the samples and flow are representative of the discharge
during that sampling period.
Monthly Average (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar month. In the case of fecal
coliform or other bacterial parameters or indicators, the geometric mean of such discharges.
Permit Issuing Authority
The Director of the Division of Water Resources.
Quarterly Average (concentration limit)
The arithmetic mean of all samples taken over a calendar quarter.
Severe property damage
Substantial physical damage to property, damage to the treatment facilities which causes them to become inoperable, or
substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a
bypass. Severe property damage excludes economic loss caused by delays in production.
Toxic Pollutant:
Any pollutant listed as toxic under Section 307(a)(1) of the CWA.
Upset
An incident beyond the reasonable control of the Permittee causing unintentional and temporary noncompliance with
permit effluent limitations and/or monitoring requirements. An upset does not include noncompliance caused by
operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive
maintenance, or careless or improper operation.
Weekly Average (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar week. In the case of fecal
coliform or other bacterial parameters or indicators, the geometric mean of such discharges.
Section B. General Conditions
1. Duty to Comply
The Permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of
the CWA and is grounds for enforcement action; for permit termination, revocation and reissuance, or
modification; or denial of a permit renewal application [40 CFR 122.41].
a. The Permittee shall comply with effluent standards or prohibitions established under section 307(a) of the
CWA for toxic pollutants and with standards for sewage sludge use or disposal established under section
405(d) of the CWA within the time provided in the regulations that establish these standards or prohibitions or
standards for sewage sludge use or disposal, even if the permit has not yet been modified to incorporate the
requirement.
b. The CWA provides that any person who violates section[s] 301, 302, 306, 307, 308, 318 or 405 of the Act, or
any permit condition or limitation implementing any such sections in a permit issued under section 402, or any
requirement imposed in a pretreatment program approved under sections 402(a)(3) or 402(b)(8) of the Act, is
subject to a civil penalty not to exceed $37,500 per day for each violation. [33 USC 1319(d) and 40 CFR
122.41(a)(2)]
c. The CWA provides that any person who negligently violates sections 301, 302, 306, 307, 308, 318, or 405 of
the Act, or any condition or limitation implementing any of such sections in a permit issued under section 402
of the Act, or any requirement imposed in a pretreatment program approved under section 402(a)(3) or
402(b)(8) of the Act, is subject to criminal penalties of $2,500 to $25,000 per day of violation, or
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imprisonment of not more than 1 year, or both. In the case of a second or subsequent conviction for a negligent
violation, a person shall be subject to criminal penalties of not more than $50,000 per day of violation, or by
imprisonment of not more than 2 years, or both. [33 USC 1319(c)(1) and 40 CFR 122.41(a)(2)]
d. Any person who knowingly violates such sections, or such conditions or limitations is subject to criminal
penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3 years, or both. In the
case of a second or subsequent conviction for a knowing violation, a person shall be subject to criminal
penalties of not more than $100,000 per day of violation, or imprisonment of not more than 6 years, or both.
[33 USC 1319(c)(2) and 40 CFR 122.41(a)(2)]
e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or any permit
condition or limitation implementing any of such sections in a permit issued under section 402 of the Act, and
who knows at that time that he thereby places another person in imminent danger of death or serious bodily
injury, shall, upon conviction, be subject to a fine of not more than $250,000 or imprisonment of not more than
15 years, or both. In the case of a second or subsequent conviction for a knowing endangerment violation, a
person shall be subject to a fine of not more than $500,000 or by imprisonment of not more than 30 years, or
both. An organization, as defined in section 309(c)(3)(B)(iii) of the CWA, shall, upon conviction of violating
the imminent danger provision, be subject to a fine of not more than $1,000,000 and can be fined up to
$2,000,000 for second or subsequent convictions. [40 CFR 122.41(a)(2)]
f. Under state law, a civil penalty of not more than $25,000 per violation may be assessed against any person
who violates or fails to act in accordance with the terms, conditions, or requirements of a permit. [North
Carolina General Statutes § 143-215.6A]
Any person may be assessed an administrative penalty by the Administrator for violating section 301, 302,
306, 307, 308, 318 or 405 of this Act, or any permit condition or limitation implementing any of such sections
in a permit issued under section 402 of this Act. Administrative penalties for Class I violations are not to
exceed $16,000 per violation, with the maximum amount of any Class I penalty assessed not to exceed
$37,500. Penalties for Class II violations are not to exceed $16,000 per day for each day during which the
violation continues, with the maximum amount of any Class II penalty not to exceed $177,500. [33 USC
1319(g)(2) and 40 CFR 122.41(a)(3)]
2. Duty to Mitigate
The Permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal in
violation of this permit with a reasonable likelihood of adversely affecting human health or the environment [40
CFR 122.41(d)].
3. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part II.C.4), "Upsets" (Part II.C.5) and "Power Failures"
(Part II.C.7), nothing in this permit shall be construed to relieve the Permittee from any responsibilities, liabilities,
or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309 of the Federal Act, 33 USC
1319. Furthermore, the Permittee is responsible for consequential damages, such as fish kills, even though the
responsibility for effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the Permittee
from any responsibilities, liabilities, or penalties to which the Permittee is or may be subject to under NCGS 143-
215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321. Furthermore, the Permittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive
privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any
infringement of Federal, State or local laws or regulations [40 CFR 122.41(g)].
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical structures or
facilities or the undertaking of any work in any navigable waters.
g.
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7. Severability
The provisions of this permit are severable. If any provision of this permit, or the application of any provision of
this permit to any circumstances, is held invalid, the application of such provision to other circumstances, and the
remainder of this permit, shall not be affected thereby [NCGS 150B-23].
8. Duty to Provide Information
The Permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information which the
Permit Issuing Authority may request to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit or to determine compliance with this permit. The Permittee shall also furnish to the Permit
Issuing Authority upon request, copies of records required by this permit [40 CFR 122.41(h)].
9. Duty to Reapply
If the Permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the
Permittee must apply for and obtain a new permit [40 CFR 122.41(b)].
10. Expiration of Permit
The Permittee is not authorized to discharge after the expiration date. In order to receive automatic authorization to
discharge beyond the expiration date, the Permittee shall submit such information, forms, and fees as are required
by the agency authorized to issue permits no later than 180 days prior to the expiration date unless permission for a
later date has been granted by the Director. (The Director shall not grant permission for applications to be
submitted later than the expiration date of the existing permit.) [40 CFR 122.21(d)] Any Permittee that has not
requested renewal at least 180 days prior to expiration, or any Permittee that does not have a permit after the
expiration and has not requested renewal at least 180 days prior to expiration, will subject the Permittee to
enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.
11. Signatory Requirements
All applications, reports, or information submitted to the Permit Issuing Authority shall be signed and certified [40
CFR 122.41(k)].
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a responsible
corporate officer means: (a) a president, secretary, treasurer or vice president of the corporation in charge
of a principal business function, or any other person who performs similar policy or decision making
functions for the corporation, or (b) the manager of one or more manufacturing, production, or operating
facilities, provided, the manager is authorized to make management decisions which govern the operation
of the regulated facility including having the explicit or implicit duty of making major capital investment
recommendations, and initiating and directing other comprehensive measures to assure long term
environmental compliance with environmental laws and regulations; the manager can ensure that the
necessary systems are established or actions taken to gather complete and accurate information for permit
application requirements; and where authority to sign documents has been assigned or delegated to the
manager in accordance with corporate procedures .
(2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a principal executive officer or
ranking elected official [40 CFR 122.22].
b. All reports required by the permit and other information requested by the Permit Issuing Authority shall be
signed by a person described in paragraph a. above or by a duly authorized representative of that person. A
person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the overall operation
of the regulated facility or activity, such as the position of plant manager, operator of a well or well field,
superintendent, a position of equivalent responsibility, or an individual or position having overall
responsibility for environmental matters for the company. (A duly authorized representative may thus be
either a named individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Permit Issuing Authority [40 CFR 122.22]
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c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer accurate because
a different individual or position has responsibility for the overall operation of the facility, a new authorization
satisfying the requirements of paragraph (b) of this section must be submitted to the Director prior to or
together with any reports, information, or applications to be signed by an authorized representative [40 CFR
122.22]
d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make the following
certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or
those persons directly responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fines and imprisonment for knowing violations."
12. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the
Permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned changes
or anticipated noncompliance does not stay any permit condition [40 CFR 122.41(0].
13. Permit Modification, Revocation and Reissuance, or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and modifying the permit,
revoking and reissuing the permit, or terminating the permit as allowed by the laws, rules, and regulations
contained in Title 40, Code of Federal Regulations, Parts 122 and 123; Title 15A of the North Carolina
Administrative Code, Subchapter 02H .0100; and North Carolina General Statute 143.215.1 et. al.
14. Annual Administering and Compliance Monitoring Fee Requirements
The Permittee must pay the annual administering and compliance monitoring fee within thirty days after being
billed by the Division. Failure to pay the fee in a timely manner in accordance with 15A NCAC 02H .0105(b)(2)
may cause this Division to initiate action to revoke the permit.
Section C. Operation and Maintenance of Pollution Controls
1. Certified Operator
Owners of classified water pollution control systems must designate operators, certified by the Water Pollution
Control System Operators Certification Commission (WPCSOCC), of the appropriate type and grade for the
system, and, for each classification must [T15A NCAC 08G .0201]:
a. designate one Operator In Responsible Charge (ORC) who possesses a valid certificate of the type and grade at
least equivalent to the type and grade of the system;
b. designate one or more Back-up Operator(s) in Responsible Charge (Back-up ORCs) who possesses a valid
certificate of the type of the system and no more than one grade less than the grade of the system, with the
exception of no backup operator in responsible charge is required for systems whose minimum visitation
requirements are twice per year; and
c. submit a signed completed "Water Pollution Control System Operator Designation Form" to the Commission
(or to the local health department for owners of subsurface systems) countersigned by the designated certified
operators, designating the Operator in Responsible Charge (ORC) and the Back-up Operator in Responsible
Charge (Back-up ORC):
(1) 60 calendar days prior to wastewater or residuals being introduced into a new system; or
(2) within 120 calendar days following:
➢ receiving notification of a change in the classification of the system requiring the designation of a new
Operator in Responsible Charge (ORC) and Back-up Operator in Responsible Charge (Back-up ORC)
of the proper type and grade; or
➢ a vacancy in the position of Operator in Responsible Charge (ORC) or Back-up Operator in
Responsible Charge (Back-up ORC).
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(3) within seven calendar days of vacancies in both ORC and Back-up ORC positions replacing or designating
at least one of the responsibilities.
The ORC of each Class I facility (or the Back-up ORC, when acting as surrogate for the ORC) must:
➢ Visit the facility as often as is necessary to insure proper operation of the treatment system; the treatment
facility must be visited at least weekly
➢ Comply with all other conditions of 15A NCAC 08G .0204.
The ORC of each Class II, III and IV facility (or the Back-up ORC, when acting as surrogate for the ORC) must:
➢ Visit the facility as often as is necessary to insure proper operation of the treatment system; the treatment
facility must be visited at least five days per week, excluding holidays
➢ Properly manage and document daily operation and maintenance of the facility
➢ Comply with all other conditions of 15A NCAC 08G .0204.
2. Proper Operation and Maintenance
The Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control
(and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions
of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality
assurance procedures. This provision requires the Permittee to install and operate backup or auxiliary facilities only
when necessary to achieve compliance with the conditions of the permit [40 CFR 122.41(e)].
NOTE: Properly and officially designated operators are fully responsible for all proper operation and maintenance
of the facility, and all documentation required thereof, whether acting as a contract operator [subcontractor] or a
member of the Permittee's staff.
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this permit [40 CFR 122.41(c)].
4. Bypassing of Treatment Facilities
a. Bypass not exceeding limitations [40 CFR 122.41(m)(2)]
The Permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but
only if it also is for essential maintenance to assure efficient operation. These bypasses are not subject to the
provisions of Paragraphs b. and c. of this section.
b. Notice [40 CFR 122.41(m)(3)]
(1) Anticipated bypass. If the Permittee knows in advance of the need for a bypass, it shall submit prior notice,
if possible at least ten days before the date of the bypass; including an evaluation of the anticipated quality
and effect of the bypass.
(2) Unanticipated bypass. The Permittee shall submit notice of an unanticipated bypass as required in Part
II.E.6. (24-hour notice).
c. Prohibition of Bypass
(1) Bypass from the treatment facility is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe property damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities,
retention of untreated wastes or maintenance during normal periods of equipment downtime. This
condition is not satisfied if adequate backup equipment should have been installed in the exercise of
reasonable engineering judgment to prevent a bypass which occurred during normal periods of
equipment downtime or preventive maintenance; and
(C) The Permittee submitted notices as required under Paragraph b. of this section.
(2) Bypass from the collection system is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for a bypass as provided in any current or future system -wide collection system
permit associated with the treatment facility.
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(3) The Permit Issuing Authority may approve an anticipated bypass, after considering its adverse effects, if
the Permit Issuing Authority determines that it will meet the three conditions listed above in Paragraph c.
(1) of this section.
5. Upsets
a. Effect of an upset [40 CFR 122.41(n)(2)]: An upset constitutes an affirmative defense to an action brought for
noncompliance with such technology based permit effluent limitations if the requirements of paragraph b. of
this condition are met. No determination made during administrative review of claims that noncompliance was
caused by upset, and before an action for noncompliance, is final administrative action subject to judicial
review.
b. Conditions necessary for a demonstration of upset: Any Permittee who wishes to establish the affirmative
defense of upset shall demonstrate, through properly signed, contemporaneous operating logs, or other relevant
evidence that:
(1) An upset occurred and that the Permittee can identify the cause(s) of the upset;
(2) The Permittee facility was at the time being properly operated; and
(3) The Permittee submitted notice of the upset as required in Part II.E.6.(b) of this permit.
(4) The Permittee complied with any remedial measures required under Part II.B.2. of this permit.
c. Burden of proof [40 CFR 122.41(n)(4)]: The Permittee seeking to establish the occurrence of an upset has
the burden of proof in any enforcement proceeding.
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters
shall be utilized/disposed of in accordance with NCGS 143-215.1 and in a manner such as to prevent any pollutant
from such materials from entering waters of the State or navigable waters of the United States except as permitted
by the Commission. The Permittee shall comply with all applicable state and Federal regulations governing the
disposal of sewage sludge, including 40 CFR 503, Standards for the Use and Disposal of Sewage Sludge; 40 CFR
Part 258, Criteria For Municipal Solid Waste Landfills; and 15A NCAC Subchapter 2T, Waste Not Discharged To
Surface Waters. The Permittee shall notify the Permit Issuing Authority of any significant change in its sludge use
or disposal practices.
7. Power Failures
The Permittee is responsible for maintaining adequate safeguards (as required by 15A NCAC 02H .0124) to
prevent the discharge of untreated or inadequately treated wastes during electrical power failures either by means
of alternate power sources, standby generators or retention of inadequately treated effluent.
Section D. Monitoring and Records
1. Representative Sampling
Samples collected and measurements taken, as required herein, shall be representative of the permitted discharge.
Samples collected at a frequency less than daily shall be taken on a day and time that is representative of the
discharge for the period the sample represents. All samples shall be taken at the monitoring points specified in this
permit and, unless otherwise specified, before the effluent joins or is diluted by any other wastestream, body of
water, or substance. Monitoring points shall not be changed without notification to and the approval of the Permit
Issuing Authority [40 CFR 122.41(j)].
2. Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each month and reported on a
monthly Discharge Monitoring Report (DMR) Form (MR 1, 1.1, 2, 3) or alternative forms approved by the
Director, postmarked no later than the last calendar day of the month following the completed reporting period.
The first DMR is due on the last day of the month following the issuance of the permit or in the case of a new
facility, on the last day of the month following the commencement of discharge. Duplicate signed copies of these,
and all other reports required herein, shall be submitted to the following address:
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NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected
and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The
devices shall be installed, calibrated and maintained to ensure that the accuracy of the measurements is consistent
with the accepted capability of that type of device. Devices selected shall be capable of measuring flows with a
maximum deviation of less than 10% from the true discharge rates throughout the range of expected discharge
volumes. Flow measurement devices shall be accurately calibrated at a minimum of once per year and maintained
to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device.
The Director shall approve the flow measurement device and monitoring location prior to installation.
Once -through condenser cooling water flow monitored by pump logs, or pump hour meters as specified in Part I of
this permit and based on the manufacturer's pump curves shall not be subject to this requirement.
4. Test Procedures
Laboratories used for sample analysis must be certified by the Division. Permittees should contact the Division's
Laboratory Certification Section (919 733-3908) or visit https://deq.nc.gov/about/divisions/water-resources/water-
resources-data/water-sciences-home-page/laboratory-certification-branch for information regarding laboratory
certifications.
Facilities whose personnel are conducting testing of field -certified parameters only must hold the appropriate field
parameter laboratory certifications.
Test procedures for the analysis of pollutants shall conform to the EMC regulations (published pursuant to NCGS
143-215.63 et. seq.), the Water and Air Quality Reporting Acts, and to regulations published pursuant to Section
304(g), 33 USC 1314, of the CWA (as amended), and 40 CFR 136; or in the case of sludge use or disposal,
approved under 40 CFR 136, unless otherwise specified in 40 CFR 503, unless other test procedures have been
specified in this permit [40 CFR 122.41].
To meet the intent of the monitoring required by this permit, all test procedures must produce minimum detection
and reporting levels that are below the permit discharge requirements and all data generated must be reported down
to the minimum detection or lower reporting level of the procedure. If no approved methods are determined
capable of achieving minimum detection and reporting levels below permit discharge requirements, then the most
sensitive (method with the lowest possible detection and reporting level) approved method must be used.
5. Penalties for Tampering
The CWA provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any monitoring
device or method required to be maintained under this permit shall, upon conviction, be punished by a fine of not
more than $10,000 per violation, or by imprisonment for not more than two years per violation, or by both. If a
conviction of a person is for a violation committed after a first conviction of such person under this paragraph,
punishment is a fine of not more than $20,000 per day of violation, or by imprisonment of not more than 4 years,
or both [40 CFR 122.41].
6. Records Retention
Except for records of monitoring information required by this permit related to the Permittee's sewage sludge use
and disposal activities, which shall be retained for a period of at least five years (or longer as required by 40 CFR
503), the Permittee shall retain records of all monitoring information, including:
➢ all calibration and maintenance records
➢ all original strip chart recordings for continuous monitoring instrumentation
➢ copies of all reports required by this permit
➢ copies of all data used to complete the application for this permit
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These records or copies shall be maintained for a period of at least 3 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time [40 CFR
122.41].
7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the Permittee shall record the
following information [40 CFR 122.41]:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
8. Inspection and Entry
The Permittee shall allow the Director, or an authorized representative (including an authorized contractor acting as
a representative of the Director), upon the presentation of credentials and other documents as may be required by
law, to;
a. Enter, at reasonable times, upon the Permittee's premises where a regulated facility or activity is located or
conducted, or where records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices,
or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise
authorized by the CWA, any substances or parameters at any location [40 CFR 122.41(i)].
Section E Reporting Requirements
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of
any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall constitute
a violation of the permit.
2. Planned Changes
The Permittee shall give notice to the Director as soon as possible of any planned physical alterations or additions
to the permitted facility [40 CFR 122.41(1)]. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for new sources at 40 CFR
122.29(b); or
b. The alteration or addition could significantly change the nature or increase the quantity of pollutants
discharged. This notification applies to pollutants subject neither to effluent limitations in the permit, nor to
notification requirements under 40 CFR 122.42(a)(1); or
c. The alteration or addition results in a significant change in the Permittee's sludge use or disposal practices, and
such alteration, addition or change may justify the application of permit conditions that are different from or
absent in the existing permit, including notification of additional use or disposal sites not reported during the
permit application process or not reported pursuant to an approved land application plan.
3. Anticipated Noncompliance
The Permittee shall give advance notice to the Director of any planned changes to the permitted facility or other
activities that might result in noncompliance with the permit [40 CFR 122.41(1)(2)].
4. Transfers
This permit is not transferable to any person without prior written notice to and approval from the Director in
accordance with 40 CFR 122.61. The Director may condition approval in accordance with NCGS 143-215.1, in
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particular NCGS 143-215.1(b)(4)b.2., and may require modification or revocation and reissuance of the permit, or
a minor modification, to identify the new permittee and incorporate such other requirements as may be necessary
under the CWA [40 CFR 122.41(1)(3), 122.61] or state statute.
5. Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit [40 CFR 122.41(1)(4)].
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part II.D.2) or forms
provided by the Director for reporting results of monitoring of sludge use or disposal practices.
b. If the Permittee monitors any pollutant more frequently than required by this permit using test procedures
approved under 40 CFR Part 136 and at a sampling location specified in this permit or other appropriate
instrument governing the discharge, the results of such monitoring shall be included in the calculation and
reporting of the data submitted on the DMR.
6. Twenty-four Hour Reporting
a. The Permittee shall report to the Director or the appropriate Regional Office any noncompliance that
potentially threatens public health or the environment. Any information shall be provided orally within 24
hours from the time the Permittee became aware of the circumstances. A written submission shall also be
provided within 5 days of the time the Permittee becomes aware of the circumstances. The written submission
shall contain a description of the noncompliance, and its cause; the period of noncompliance, including exact
dates and times, and if the noncompliance has not been corrected, the anticipated time it is expected to
continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance [40
CFR 122.41(1)(6)].
b. The Director may waive the written report on a case -by -case basis for reports under this section if the oral
report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at [phone] or [phone].
7. Other Noncompliance
The Permittee shall report all instances of noncompliance not reported under Part II.E.5 and 6. of this permit at the
time monitoring reports are submitted. The reports shall contain the information listed in Part II.E.6. of this permit
[40 CFR 122.41(1)(7)].
8. Other Information
Where the Permittee becomes aware that it failed to submit any relevant facts in a permit application, or submitted
incorrect information in a permit application or in any report to the Director, it shall promptly submit such facts or
information [40 CFR 122.41(1)(8)].
9. Noncompliance Notification
The Permittee shall report by telephone to either the central office or the appropriate regional office of the Division
as soon as possible, but in no case more than 24 hours or on the next working day following the occurrence or first
knowledge of the occurrence of any of the following:
a. Any occurrence at the water pollution control facility which results in the discharge of significant amounts of
wastes which are abnormal in quantity or characteristic, such as the dumping of the contents of a sludge
digester; the known passage of a slug of hazardous substance through the facility; or any other unusual
circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate
wastewater treatment such as mechanical or electrical failures of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass without treatment of all
or any portion of the influent to such station or facility.
Persons reporting such occurrences by telephone shall also file a written report within 5 days following first
knowledge of the occurrence. Also see reporting requirements for municipalities in Part IV.C.2.c. of this permit.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3 (a)(2) or Section 308 of the Federal Act, 33
USC 1318, all reports prepared in accordance with the terms shall be available for public inspection at the offices
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of the Division. As required by the Act, effluent data shall not be considered confidential. Knowingly making any
false statement on any such report may result in the imposition of criminal penalties as provided for in NCGS 143-
215.1(b)(2) or in Section 309 of the Federal Act.
11. Penalties for Falsification of Reports
The CWA provides that any person who knowingly makes any false statement, representation, or certification in
any record or other document submitted or required to be maintained under this permit, including monitoring
reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine of not more than
$25,000 per violation, or by imprisonment for not more than two years per violation, or by both [40 CFR 122.41].
12. Annual Performance Reports
Permittees who own or operate facilities that primarily collect or treat municipal or domestic wastewater and have
an average annual flow greater than 200,000 gallons per day shall provide an annual report to the Permit Issuing
Authority and to the users/customers served by the Permittee (NCGS 143-215.1C). The report shall summarize the
performance of the collection or treatment system, as well as the extent to which the facility was compliant with
applicable Federal or State laws, regulations and rules pertaining to water quality. The report shall be provided no
later than sixty days after the end of the calendar or fiscal year, depending upon which annual period is used for
evaluation.
The report shall be sent to:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
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PART III
OTHER REQUIREMENTS
Section A. Construction
a. The Permittee shall not commence construction of wastewater treatment facilities, nor add to the plant's treatment
capacity, nor change the treatment process(es) utilized at the treatment plant unless (1) the Division has issued an
Authorization to Construct (AtC) permit or (2) the Permittee is exempted from such AtC permit requirements
under Item b. of this Section.
b. In accordance with NCGS 143-215.1(a5) [SL 2011-394], no permit shall be required to enter into a contract for the
construction, installation, or alteration of any treatment work or disposal system or to construct, install, or alter any
treatment works or disposal system within the State when the system's or work's principle function is to conduct,
treat, equalize, neutralize, stabilize, recycle, or dispose of industrial waste or sewage from an industrial facility and
the discharge of the industrial waste or sewage is authorized under a permit issued for the discharge of the
industrial waste or sewage into the waters of the State. Notwithstanding the above, the permit issued for the
discharge may be modified if required by federal regulation.
Issuance of an AtC will not occur until Final Plans and Specifications for the proposed construction have been
submitted by the Permittee and approved by the Division.
c.
Section B. Groundwater Monitoring
The Permittee shall, upon written notice from the Director, conduct groundwater monitoring as may be required to
determine the compliance of this NPDES permitted facility with the current groundwater standards.
Section C. Changes in Discharges of Toxic Substances
The Permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe (40 CFR 122.42):
a. That any activity has occurred or will occur which would result in the discharge, on a routine or frequent basis, of
any toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the following
"notification levels";
(1) One hundred micrograms per liter (100 µg/L);
(2) Two hundred micrograms per liter (200 µg/L) for acrolein and acrylonitrile; five hundred micrograms per liter
(500 µg/L) for 2,4-dinitrophenol and for 2-methyl-4,6-dinitrophenol; and one milligram per liter (1 mg/L) for
antimony;
(3) Five times the maximum concentration value reported for that pollutant in the permit application.
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine or infrequent
basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the
following "notification levels";
(1) Five hundred micrograms per liter (500 µg/L);
(2) One milligram per liter (1 mg/L) for antimony;
(3) Ten times the maximum concentration value reported for that pollutant in the permit application.
Section D. Facility Closure Requirements
The Permittee must notify the Division at least 90 days prior to the closure of any wastewater treatment system covered
by this permit. The Division may require specific measures during deactivation of the system to prevent adverse
impacts to waters of the State. This permit cannot be rescinded while any activities requiring this permit continue at the
permitted facility.
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PART IV
SPECIAL CONDITIONS FOR MUNICIPAL FACILITIES
Section A. Definitions
In addition to the definitions in Part II of this permit, the following definitions apply to municipal facilities:
Indirect Discharge or Industrial User
Any non -domestic source that discharges wastewater containing pollutants into a POTW regulated under section
307(b), (c) or (d) of the CWA. [40 CFR 403.3 (i) and (j) and 15A NCAC 02H .0903(b)(11)]
Interference
Inhibition or disruption of the POTW treatment processes; operations; or its sludge process, use, or disposal which
causes or contributes to a violation of any requirement of the Permittee's (or any satellite POTW's if different from the
Permittee) NPDES, collection system, or non -discharge permit or prevents sewage sludge use or disposal in
compliance with specified applicable State and Federal statutes, regulations, or permits. [15A NCAC 02H
.0903(b)(14)]
Pass Through
A discharge which exits the POTW into waters of the State in quantities or concentrations which, alone or with
discharges from other sources, causes a violation, including an increase in the magnitude or duration of a violation, of
the Permittee's (or any satellite POTW's, if different from the Permittee) NPDES, collection system, or non -discharge
permit. [15A NCAC 02H .0903(b)(23)]
Publicly Owned Treatment Works (POTW)
A treatment works as defined by Section 212 of the CWA, which is owned by a State or local government organization.
This definition includes any devices and systems used in the storage, treatment, recycling and reclamation of municipal
sewage or industrial wastes of a liquid nature. It also includes the collection system, as defined in 15A NCAC 2T
.0402, only if it conveys wastewater to a POTW treatment plant. The term also means the local government
organization, or municipality, as defined in section 502(4) of the CWA, which has jurisdiction over indirect discharges
to and the discharges from such a treatment works. In this context, the organization may be the owner of the POTW
treatment plant or the owner of the collection system into which an indirect discharger discharges. This second type of
POTW may be referred to as a "satellite POTW organization." [15A NCAC 02H .0903(b)(26)]
"Significant Industrial User" or "SIU"
An Industrial User that discharges wastewater into a publicly owned treatment works and that [15A NCAC 02H
.0903(b)(33)]:
1. Discharges an average of 25,000 gallons per day or more of process wastewater to the POTW (excluding sanitary,
noncontact cooling and boiler blowdown wastewaters); or
2. Contributes process wastewater which makes up five percent or more of the NPDES or non -discharge permitted
flow limit or organic capacity of the POTW treatment plant. In this context, organic capacity refers to BOD, TSS
and ammonia; or
3. Is subject to categorical standards under 40 CFR Part 403.6 and 40 CFR Parts 405-471; or
4. Is designated as such by the Permittee on the basis that the Industrial User has a reasonable potential for adversely
affecting the POTW's operation or for violating any pretreatment standard or requirement, or the POTW's effluent
limitations and conditions in its NPDES or non -discharge permit, or to limit the POTW's sludge disposal options;
5. Subject to approval under 15A NCAC 02H .0907(b), the Permittee may determine that an Industrial User meeting
the criteria in paragraphs 1 or 2 of this definition above has no reasonable potential for adversely affecting the
POTW's operation or for violating any pretreatment standard or requirement, the POTW's effluent limitations and
conditions in its NPDES or non -discharge permit, or to limit the POTW's sludge disposal options, and thus is not a
Significant Industrial User (SIU); or
6. Subject to approval under 15A NCAC 02H .0907(b), the Permittee may determine that an Industrial User meeting
the criteria in paragraph 3 of this definition above meets the requirements of 40 CFR Part 403.3(v)(2) and thus is a
non -significant categorical Industrial User.
Section B. Publicly Owned Treatment Works (POTWs)
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1. Effluent limitations are listed in Part I of this permit. Other pollutants attributable to inputs from Industrial Users
discharging to the POTW may be present in the Permittee's discharge. At such time as sufficient information
becomes available to establish limitations for such pollutants, this permit may be revised to specify effluent
limitations for any or all of such other pollutants in accordance with best practicable technology or water quality
standards.
2. Prohibited Discharges
a. The Permittee shall develop and enforce their Pretreatment Program to implement the prohibition against the
introduction of pollutants or discharges into the waste treatment system or waste collection system which
cause or contribute to Pass Through or Interference as defined in 15A NCAC 02H .0900 and 40 CFR 403. [40
CFR 403.5(a)(1)]
b. The Permittee shall develop and enforce their Pretreatment Program to implement the prohibitions against the
introduction of the following wastes in the waste treatment or waste collection system [40 CFR 403.5(b)]:
(1) Pollutants which create a fire or explosion hazard in the POTW, including, but not limited to,
wastestreams with a closed cup flashpoint of less than 140 degrees Fahrenheit or 60 degrees Centigrade
using the test methods specified in 40 CFR 261.21;
(2) Pollutants which cause corrosive structural damage to the POTW, but in no case discharges with pH lower
than 5.0, unless the works is specifically designed to accommodate such discharges;
Solid or viscous pollutants in amounts which cause obstruction to the flow in the POTW resulting in
Interference;
(4) Any pollutant, including oxygen demanding pollutants (BOD, etc.) released in a Discharge at a flow rate
and/or pollutant concentration which will cause Interference with the POTW;
Heat in amounts which will inhibit biological activity in the POTW resulting in Interference, but in no
case heat in such quantities that the temperature at the POTW Treatment Plant exceeds 40°C (104°F)
unless the Division, upon request of the POTW, approves alternate temperature limits;
(6) Petroleum oil, non -biodegradable cutting oil, or products of mineral oil origin in amounts that will cause
Interference or Pass Through;
Pollutants which result in the presence of toxic gases, vapors, or fumes within the POTW in a quantity that
may cause acute worker health and safety problems; or
Any trucked or hauled pollutants, except at discharge points designated by the POTW.
All POTWs must provide adequate notice to the Director of the following [40 CFR 122.42(b)]:
1. Any new introduction of pollutants into the POTW from an indirect discharger, regardless of the means of
transport, which would be subject to section 301 or 306 of CWA if it were directly discharging those pollutants;
and
2. Any substantial change in the volume or character of pollutants being introduced by an indirect discharger as
influent to that POTW at the time of issuance of the permit.
3. For purposes of this paragraph, adequate notice shall include information on (1) the quality and quantity of effluent
introduced into the POTW, and (2) any anticipated impact that may result from the change of the quantity or
quality of effluent to be discharged from the POTW.
Section C. Municipal Control of Pollutants from Industrial Users.
(3)
(5)
(7)
(8)
c. The Permittee shall investigate the source of all discharges into the POTW, including slug loads and other
unusual discharges, which have the potential to adversely impact the Permittee's Pretreatment Program and/or
the operation of the POTW.
The Permittee shall report such discharges into the POTW to the Director or the appropriate Regional Office.
Any information shall be provided orally within 24 hours from the time the Permittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the Permittee becomes
aware of the circumstances. The written submission shall contain a description of the discharge; the
investigation into possible sources; the period of the discharge, including exact dates and times; if the
discharge has not ceased, the anticipated time it is expected to continue; and steps taken or planned to reduce,
eliminate, and prevent reoccurrence of the noncompliance,
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3. With regard to the effluent requirements listed in Part I of this permit, it may be necessary for the Permittee to
supplement the requirements of the Federal Pretreatment Standards (40 CFR, Part 403) to ensure compliance by
the Permittee with all applicable effluent limitations. Such actions by the Permittee may be necessary regarding
some or all of the industries discharging to the municipal system.
4. The Permittee shall require any Industrial User (IU) discharging to the POTW to meet Federal Pretreatment
Standards developed under Section 307(b) of the Act as amended (which includes categorical standards and
specific local limits, best management practices and narrative requirements). Prior to accepting wastewater from
any Significant Industrial User (SIU), the Permittee shall either develop and submit to the Division a new
Pretreatment Program or, as necessary, a modification of an existing Pretreatment Program, for approval as
required under section D below as well as 15A NCAC 02H .0907(a) and (b). [40 CFR 122.44(j)(2)]
5. This permit shall be modified, or alternatively, revoked and reissued, to incorporate or modify an approved POTW
Pretreatment Program or to include a compliance schedule for the development of a POTW Pretreatment Program
as required under Section 402 (b)(8) of the CWA and implementing regulations or by the requirements of the
approved State pretreatment program, as appropriate.
Section D. Pretreatment Programs
Under authority of sections 307 (b) and (c) and 402(b)(8) of the CWA and implementing regulations 40 CFR 403,
North Carolina General Statute 143-215.3(14) and implementing regulations 15A NCAC 02H .0900, and in accordance
with the approved pretreatment program, all provisions and regulations contained and referenced in the pretreatment
program submittal are an enforceable part of this permit. [40 CFR 122.44(j)(2)]
The Permittee shall operate its approved pretreatment program in accordance with Section 402(b)(8) of the CWA, 40
CFR 403, 15A NCAC 02H .0900, and the legal authorities, policies, procedures, and financial provisions contained in
its pretreatment program submission and Division approved modifications thereof. Such operation shall include but is
not limited to the implementation of the following conditions and requirements. Terms not defined in Part II or Part IV
of this permit are as defined in 15A NCAC 02H .0903 and 40 CFR 403.3.
1. Sewer Use Ordinance (SUO)
The Permittee shall maintain adequate legal authority to implement its approved pretreatment program. [15A
NCAC 02H .0903(b)(32), .0905 and .0906(b)(1); 40 CFR 403.8(f)(1) and 403.9(b)(1) and (2)]
2. Industrial Waste Survey (IWS)
The Permittee shall implement an IWS consisting of the survey of users of the POTW collection system or
treatment plant, as required by 40 CFR 403.8(f)(2)(i-iii) and 15A NCAC 02H .0905 [also 40 CFR 122.44(j)(1)],
including identification of all Industrial Users that may have an impact on the POTW and the character and amount
of pollutants contributed to the POTW by these Industrial Users and identification of those Industrial Users
meeting the definition of SIU. Where the Permittee accepts wastewater from one or more satellite POTWs, the
IWS for the Permittee shall address all satellite POTW services areas, unless the pretreatment program in those
satellite service areas is administered by a separate Permittee with an approved Pretreatment Program. The
Permittee shall submit a summary of its IWS activities to the Division at least once every five years, and as
required by the Division. The IWS submission shall include a summary of any investigations conducted under
paragraph C.2.c. of this Part. [15A NCAC 02H .0903(b)(13), .0905 and .0906(b)(2); 40 CFR 403.8(0(2) and 403.9]
3. Monitoring Plan
The Permittee shall implement a Division -approved Monitoring Plan for the collection of facility specific data to
be used in a wastewater treatment plant Headworks Analysis (HWA) for the development of specific pretreatment
local limits. Effluent data from the Plan shall be reported on the DMRs (as required by Parts II.D and II.E.5.). [15A
NCAC 02H .0903(b)(16), .0906(b)(3) and .0905]
4. Headworks Analysis (HWA) and Local Limits
The Permittee shall obtain Division approval of a HWA at least once every five years, and as required by the
Division. Within 180 days of the effective date of this permit (or any subsequent permit modification) the
Permittee shall submit to the Division a written technical evaluation of the need to revise local limits (i.e., an
updated HWA or documentation of why one is not needed) [40 CFR 122.44]. The Permittee shall develop, in
accordance with 40 CFR 403.5(c) and 15A NCAC 02H .0909, specific Local Limits to implement the prohibitions
listed in 40 CFR 403.5(a) and (b) and 15A NCAC 02H .0909. Pursuant to 40 CFR 403.5, local limits are
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enforceable Pretreatment Standards as defined by 40 CFR 403.3(1). [15A NCAC 02H .0903(b)(10), .0905, and
.0906(b)(4)]
5. Industrial User Pretreatment Permits (IUP) & Allocation Tables
In accordance with NCGS 143-215.1, the Permittee shall issue to all Significant Industrial Users, permits for
operation of pretreatment equipment and discharge to the Permittee's collection system or treatment works. These
permits shall contain limitations, sampling protocols, reporting requirements, appropriate standard and special
conditions, and compliance schedules as necessary for the installation of treatment and control technologies to
assure that their wastewater discharge will meet all applicable pretreatment standards and requirements. The
Permittee shall maintain a current Allocation Table (AT) which summarizes the results of the HWA and the limits
from all IUPs. Permitted IUP loadings for each parameter cannot exceed the treatment capacity of the POTW as
determined by the HWA. [15A NCAC 02H .0906(b)(6), .0909, .0916, and .0917; 40 CFR 403.5, 403.8(f)(1)(iii);
NCGS 143-215.67(a)]
6. Authorization to Construct (AtC)
The Permittee shall ensure that an Authorization to Construct permit (AtC) is issued to all applicable Industrial
Users for the construction or modification of any pretreatment facility. Prior to the issuance of an AtC, the
proposed pretreatment facility and treatment process must be evaluated for its capacity to comply with all
Industrial User Pretreatment Permit (IUP) limitations. [15A NCAC 02H .0906(b)(7) and .0905; NCGS 143-
215.1(a)(8)]
7. POTW Inspection & Monitoring of their IUs
The Permittee shall conduct inspection, surveillance, and monitoring activities as described in its Division
approved pretreatment program in order to determine, independent of information supplied by Industrial Users,
compliance with applicable pretreatment standards. [15A NCAC 02H .0908(e); 40 CFR 403.8(f)(2)(v)] The
Permittee must:
a. Inspect all Significant Industrial Users (SIUs) at least once per calendar year;
b. Sample all Significant Industrial Users (SlUs) at least once per calendar year for all SIU permit -limited
parameters including flow except as allowed under 15A NCAC .0908(e); and
c. At least once per year, document an evaluation of any non -significant categorical Industrial User for
compliance with the requirements in 40 CFR 403.3(v)(2), and either continue or revoke the designation as non-
significant.
8. IU Self Monitoring and Reporting
The Permittee shall require all Industrial Users to comply with the applicable monitoring and reporting
requirements outlined in the Division -approved pretreatment program, the industry's pretreatment permit, or in 15A
NCAC 02H .0908. [15A NCAC 02H .0906(b)(5) and .0905; 40 CFR 403.8(f)(1)(v) and (2)(iii); 40 CFR
122.44(j)(2) and 40 CFR 403.12]
9. Enforcement Response Plan (ERP)
The Permittee shall enforce and obtain appropriate remedies for violations of all pretreatment standards
promulgated pursuant to section 307(b) and (c) of the CWA (40 CFR 405 et. seq.), prohibitive discharge standards
as set forth in 40 CFR 403.5 and 15A NCAC 02H .0909, specific local limitations, and other pretreatment
requirements. All remedies, enforcement actions and other, shall be consistent with the Enforcement Response
Plan (ERP) approved by the Division. [15A NCAC 02H .0903(b)(7), .0906(b)(8) and .0905; 40 CFR 403.8(f)(5)]
10. Pretreatment Annual Reports (PAR)
The Permittee shall report to the Division in accordance with 15A NCAC 02H .0908. In lieu of submitting annual
reports, Modified Pretreatment Programs developed under 15A NCAC 02H .0904 (b) may be required to submit a
partial annual report or to meet with Division personnel periodically to discuss enforcement of pretreatment
requirements and other pretreatment implementation issues.
For all other active pretreatment programs, the Permittee shall submit two copies of a Pretreatment Annual Report
(PAR) describing its pretreatment activities over the previous calendar year to the Division at the following
address:
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NC DEQ / Division of Water Resources / Water Quality Permitting Section
Pretreatment, Emergency Response, and Collection Systems (PERCS) Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
These reports shall be submitted by March 1 of each year and shall contain the following:
a. Narrative
A narrative summary detailing actions taken, or proposed, by the Permittee to correct significant non-
compliance and to ensure compliance with pretreatment requirements;
b. Pretreatment Program Summary (PPS)
A pretreatment program summary (PPS) on forms or in a format provided by the Division;
c. Significant Non -Compliance Report (SNCR)
A list of Industrial Users (IUs) in significant noncompliance (SNC) with pretreatment requirements, and the
nature of the violations on forms or in a format provided by the Division;
d. Industrial Data Summary Forms (IDSF)
Monitoring data from samples collected by both the POTW and the Significant Industrial Users (SIUs). These
analytical results must be reported on Industrial Data Summary Forms (IDSF) or on other forms or in a format
provided by the Division;
e. Other Information
Copies of the POTW's allocation table, new or modified enforcement compliance schedules, public notice of
IUs in SNC, a summary of data or other information related to significant noncompliance determinations for
IUs that are not considered SIUs, and any other information, upon request, which in the opinion of the Director
is needed to determine compliance with the pretreatment implementation requirements of this permit;
11. Public Notice
The Permittee shall publish annually a list of Industrial Users (IUs) that were in significant noncompliance (SNC)
as defined in the Permittee's Division -approved Sewer Use Ordinance with applicable pretreatment requirements
and standards during the previous twelve month period. This list shall be published within four months of the
applicable twelve-month period. [15A NCAC 02H .0903(b)(34), .0908(b)(5) and .0905 and 40 CFR
403.8(f)(2)(viii)]
12. Record Keeping
The Permittee shall retain for a minimum of three years records of monitoring activities and results, along with
support information including general records, water quality records, and records of industrial impact on the
POTW and shall retain all other Pretreatment Program records as required by 15A NCAC 02H .0908(f). [15A
NCAC 02H .0908(f); 40 CFR 403.12(o)]
13. Pretreatment Program Resources
The Permittee shall maintain adequate funding and qualified personnel to accomplish the objectives of its approved
pretreatment program. and retain a written description of those current levels of inspection. [15A NCAC 02H
.0906(b)(9) and (10) and .0905; 40 CFR 403.8(0(3), 403.9(b)(3)]
14. Modification to Pretreatment Programs
Modifications to the approved pretreatment program including but not limited to local limits modifications, POTW
monitoring of their Significant Industrial Users (SIUs), and Monitoring Plan modifications, shall be considered a
permit modification and shall be governed by 40 CFR 403.18, 15 NCAC 02H .0114 and 15A NCAC 02H .0907.
Version 11/09/2011.2

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Mr. Daniel F. McLawhorn, Chairman
Neuse River Compliance Association
PO Box 1410
Clayton, North Carolina 27528-1410
Dear Mr. McLawhorn:
NORTH CAROLINA
Environmental Quality
December 12, 2018
Subject: Issuance of NPDES Permit NCC000001
Neuse River Compliance Association
In accordance with the application for discharge permit dated June 28, 2018, the Division is
forwarding herewith the NPDES permit for the Neuse River Compliance Association. This
permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and
to the Memorandum of Agreement between North Carolina and the U.S. Environmental
Protection Agency dated October 15, 2007, or as subsequently amended.
The Division published notices in newspapers of general circulation in the affected counties,
inviting public comments on the draft permit. No comments were received. Because no
revisions were proposed, the Association's Estuary TN Limitation remains at 1,187,213 lb/yr.
If any requirements contained in this permit are unacceptable to you, you have the right to an
adjudicatory hearing upon written request within thirty (30) days following receipt of this
letter. This request must be in the form of a written petition, conforming to Chapter 150B of the
North Carolina General Statutes, and filed with the office of Administrative Hearings, Post
Office Drawer 27447, Raleigh, North Carolina 27611-7447. Unless such a demand is made, this
permit shall be final and binding.
Please take notice that this permit is not transferable except after notice to the Division of Water
Resources. The Division of Water Resources may require modification or revocation and
reissuance of the permit.
D_EQ )
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

Issuance of NPDES Permit NCC000001
December 12, 2018
This permit does not affect the legal requirements to obtain other permits that may be required
by the Division of Water Resources, the Division of Energy, Mineral, and Land Resources, the
Coastal Area Management Act, or any other Federal or local governmental permit.
If you have any questions concerning the permit, please contact Mike Templeton at (919) 807-
6402 or [e-mail].
Enclosures: Final NPDES Permit No. NCC000001
Copies (w/ encl.):
eCopies (w/ encl.):
Sincerely,
Linda Culpepper
Director
Haywood Phthisic, Executive Director, NRCA (same address)
Raleigh and Washington Regional Offices, DWR/Surface Water
NPDES Files
Central Files
Glenn Dunn, Poyner & Spruill
EPA Region 4 NPDES Program
Nora Deamer, Basinwide Planning Unit

Permit No. NCC000001
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended, the
The Neuse River Compliance Association
and Its Co-Permittee Members
are hereby authorized to discharge Total Nitrogen from the Co-Permittee Member treatment facilities
listed herein
to receiving waters in the Neuse River Basin in accordance with effluent limitations, monitoring and
reporting requirements, and other conditions set forth in this permit.
This permit shall become effective January 1, 2019.
This permit and the authorization to discharge shall expire at midnight on December 31, 2023.
Signed this day December 12, 2018.
er Linda Culpepper, Director
Division of Water Resources
By Authority of the Environmental Management Commission

Permit No. NCC000001
Certificate of Coverage
Page ii of ii
TABLE OF CONTENTS
CERTIFICATE OF COVERAGE i
PART I - SPECIAL CONDITIONS 1
SECTION A - WASTEWATER CONTROLS
A.(1.) DEFINITIONS 1
A.(2.) CO-PERMITTEES AND TN ALLOCATIONS 2
A.(3.) EFFLUENT LIMITATIONS 2
A.(4.) MONITORING REQUIREMENTS 3
A.(5.) REPORTING REQUIREMENTS 4
A.(6.) COMPLIANCE 4
PARTS II & III - STANDARD CONDITIONS 1
SECTION A - APPLICABILITY OF PARTS II & III 1
SECTION B - DEFINITIONS 1
SECTION C - GENERAL CONDITIONS 2
SECTION D - MONITORING AND RECORDS 5
SECTION E - REPORTING REQUIREMENTS 7
PART III - OTHER REQUIREMENTS 9
APPENDIX A - CO-PERMITTEES, TRANSPORT FACTORS, AND TN ALLOCATIONS 1
APPENDIX B - POINT SOURCE FACILITIES ASSIGNED TOTAL NITROGEN ALLOCATIONS 1

Permit No. NCC000001
Part I, Page 1 of 5
PART I
SPECIAL CONDITIONS
A.(1.) DEFINITIONS
(a.) Active TN Allocation: Allocation that is included in calculation of TN Load Limits. Allocation
held by a permittee is active by default but may be designated as reserve allocation by the
Division or at the request of the permittee. (See also Reserve TN Allocation.)
(b.) Allocation (or "TN Allocation"): (1) The mass quantity (as of TN) that a discharger or group of
dischargers (such as the Association) is potentially allowed to release to surface waters in
accordance with the Neuse River rule. TN Allocations may be expressed as Estuary TN Allocation
or as the equivalent Discharge TN Allocation; also as active or reserve allocation. (2) In practice,
the term can refer to a permittee's or group's allocation as a whole or to some lesser quantity.
(c.) Association: The Neuse River Compliance Association, a not -for -profit corporation comprised of
NPDES-permitted dischargers in the Neuse River Basin; established voluntarily under the Neuse
Wastewater rule to meet the aggregate Estuary TN Allocation of its Co-Permittee Members.
(d.) Co-Permittee Members: Those NPDES dischargers that for a given calendar year are members of
the Association and are listed in Appendix A of this permit.
(e.) Discharge TN Allocation: TN Allocation specified as applying at the point of discharge (or "end -
of -pipe").
(f.) Discharge TN Load: Actual TN Load measured at a Co-Permittee Member's point of discharge
(or "end -of -pipe").
(g.) Estuary: The Neuse River estuary, which extends from approximately Streets Ferry to the
Pamlico Sound.
(h.) Estuary TN Allocation: TN Allocation specified as applying at the estuary. A Co-Permittee
Member's Estuary TN Allocation is equivalent to its Discharge TN Allocation multiplied by the
applicable Transport Factor.
(i.) Estuary TN Limitation: The sum of active TN allocations held by the Association and its Co-
Permittee Members (group limit) or a Co-Permittee Member (individual limits), as listed in
Appendix A of this permit.
(j.) Estuary TN Load: TN Load estimated to be delivered to the estuary. A Co-Permittee Member's
Estuary TN Load is equivalent to its Discharge TN Load multiplied by the applicable Transport
Factor.
(k.) Limitation (or "TN Limit(ation)" or "TN Load Limit(ation)"): The mass quantity of TN specified
in an NPDES permit as the maximum that an individual discharger or group of dischargers is
authorized to discharge to surface waters. The TN Limitation is the sum of active allocations held
by an individual Co-Permittee Member (in the case of individual limitations) or held in the
aggregate by the Association and its Co-Permittee Members (in the case of the group limitation).
For the purposes of this permit, TN Load Limits are expressed in terms of Estuary TN Load.
(1.) Load (or "TN Load"): The actual mass quantity (as of TN) that a discharger or group of
dischargers releases into surface waters of the Neuse River Basin. TN Loads may be expressed as
Discharge TN Load or as the equivalent Estuary TN Load.
(m.) Neuse Wastewater Rule: The Neuse River Basin Nutrient Sensitive Waters Management Strategy:
Wastewater Discharge Requirements rule (T15A NCAC 2B .0234)
(n.) Regionalization: The consolidation of wastewater collection and/or treatment systems that
results in the elimination of one or more NPDES-permitted discharges.
(o.) Reserve TN Allocation: Allocation that is not included in calculation of TN Limits. The Division
may designate allocation as reserve when water quality -based limits established to prevent

(p.)
(q.)
Permit No. NCC000001
Part I, Page 2 of 5
localized impacts render that allocation inactive; when treatment of the allocation as active would
be inconsistent with the Neuse Wastewater rule. (See also Active TN Allocation.)
Total Maximum Daily Load (of TMDL): (1) Generally, the allowable load of a pollutant that can
be discharged to a water body without causing loss of that water's designated uses. (2) In the
context of this permit, refers to Phase II of the Total Maximum Daily Load for Total Nitrogen to the
Neuse River Estuary, North Carolina, approved by the U.S. Environmental Protection Agency on
March 19, 2002, and subsequent revisions approved by the EPA.
Total Nitrogen (TN): The sum of the organic, nitrate, nitrite, and ammonia species of nitrogen in
a water or wastewater.
(r.) Transport Factor: Fraction of the TN in a discharge that is predicted to reach the estuary, as
determined by the Division.
(s.) Water Quality -Based Effluent Limitations (WOBELs): Limitations calculated specifically to
ensure that a discharge does not cause an exceedance of water quality standards either in the
vicinity of the discharge or further downstream. In the context of this permit, applies only to
Total Nitrogen.
A.(2.) CO-PERMITTEES AND TN ALLOCATIONS
(a.) Co-Permittees to this permit shall be the Neuse River Compliance Association (the "Association")
and each of its Co-Permittee Members. The Co-Permittee Members, the Transport Factors
assigned to each, the Members' individual TN allocations, and the Association Estuary TN
Allocation shall be as listed in Appendix A, which is hereby incorporated into this permit in its
entirety.
Upon timely and proper notification by the Association as described elsewhere in this permit, the
Division shall revise Appendix A to incorporate changes in Association membership, allowable
changes in TN Allocations, or reapportionment by the Association.
(b.)
(i.)
Changes in membership.
(A) Enrollment. In the event that a discharger is admitted to the Association, the Division
shall add the discharger and its TN Allocation to Appendix A as a Co-Permittee
Member and adjust the Association's Estuary TN Allocation accordingly.
(B) Termination. In the event that a Co-Permittee Member's membership is terminated,
the Division shall delete the departing Member and its TN Allocation from Appendix
A and adjust the Association's Estuary TN Allocation accordingly.
For the purposes of this permit, allowable changes in TN Allocations include those resulting
from purchase of allocation from the Wetlands Restoration Fund or other authorized source;
purchase, sale, trade, or lease of allocation among the Association, its members, and non-
member dischargers; regionalization; and other transactions approved by the Division.
The Association and its Co-Permittee Members may reapportion their TN Allocations
among themselves; however, the Division shall only incorporate the corresponding changes
into Appendix A when specifically requested in writing by the Association and after such
changes have been incorporated into the affected individual permits.
(c.) For the purposes of this permit, Association membership, individual or Association TN
Allocations and associated limits, and allocation status (active or reserve) are effective on a
calendar year basis, and any changes shall become effective no sooner than January 1 of the
following calendar year.
A.(3.) EFFLUENT LIMITATIONS
(a.) Beginning on the effective date of this permit and lasting no later than the expiration date, the Co-
Permittees are authorized to discharge Total Nitrogen (TN) from the treatment facilities listed in
Appendix A subject to the following effluent limitations.

Permit No. NCC000001
Part I, Page 3 of 5
Association TN Limitation. In any calendar year, the Association's Estuary TN Load shall
not exceed its Estuary TN Limitation as specified in Appendix A.
Association TN Limitation: For any calendar year,
Association Estuary TN Load < Association Estuary TN Limitation
where
Association Estuary TN Load (or Limitation) = Sum of Estuary TN Loads (or Limitations)
for All Co-Permittee Members and the
Association
(ii.) Co-Permittee Member TN Limitations. In any calendar year, a Co-Permittee Member shall
be in compliance with its Estuary TN Limitation in Appendix A if:
(A) the Association Estuary TN Load complies with the Association Estuary TN
Limitation in Appendix A, or
(B) in the event that the Association Estuary TN Load exceeds its Estuary TN Limitation,
the Co-Permittee Member's Estuary TN Load does not exceed that Member's Estuary
TN Limitation in Appendix A.
(b.) Individual WQBELs: If the Division determines that a Co-Permittee Member's TN discharge has
reasonable potential to cause localized water quality impacts, it may determine an individual
water quality -based TN Limit for the Member pursuant to Neuse rule (specifically, T15A NCAC
02B .0234(6)(c), (7)(g), and (8)(h)). The Division will then propose to incorporate the new limit into
the Member's individual NPDES permit and this group permit according to standard permitting
procedures. Once the individual WQBEL becomes effective in this group permit, the Member is
subject to the new limit in lieu of the Association TN Limit. If a Member's individual WQBEL is
less than its active TN allocation, the difference is designated as reserve allocation.
(c.) Other Individual Limitations. In the event that a Co-Permittee Member's membership in the
Association is terminated, the departing Member shall no longer be eligible for coverage under
this permit and shall become subject to the TN limitation set forth in its individual NPDES
permit.
(i.) Termination of co-permittee status and re -imposition of a discharger's individual TN
limitation shall become effective only at the beginning of a calendar year (January 1).
(ii.) The Association shall notify the Division if it determines that any Member will depart at the
end of a calendar year and shall provide an accounting of all allowable changes in the
Member's TN Allocation since the most recent issuance of the departing Member's
individual NPDES permit.
(iii.) Upon receipt of the notification and accounting described above, the Division shall modify
the TN limitation in the departing Member's individual NPDES permit as necessary,
effective January 1 of the succeeding year, to reflect all allowable changes in the outgoing
Member's TN Allocation and shall also modify Appendix A of this permit accordingly.
A.(4.) MONITORING REQUIREMENTS
(a.) Each Co-Permittee Member shall continue to monitor its discharge(s) and report the results to the
Division as specified in its individual NPDES permit.
(b.) The Association shall assemble the results of its Co-Permittee Members and report the combined
results to the Division as specified in Condition A.(5.), below.

Permit No. NCC000001
Part I, Page 4 of 5
A.(5.) REPORTING REQUIREMENTS
(a.) The Association shall serve as the primary point of contact between the Division and the Co-
Permittee Members on matters related to this permit, unless otherwise noted. The Association's
responsibilities in this regard include:
(i.) preparation and submittal of any reports required by this permit or of related information
requested by the Division;
(ii.) submittal of any request for modification or renewal of this permit; and
distribution to the Co-Permittee Members of correspondence from the Division, including
but not limited to that pertaining to permit issuance, modification, and renewal; compliance;
and reporting.
Notification of Membership/ Allocation Changes. No later than July 1 of each year, the
Association shall request modification of this permit to reflect changes in membership or TN
allocations to become effective in the following calendar year. The Association may revise its
request through its Mid -Year Report or other proper written notification.
(c.) Mid -Year Report. No later than September 30 of each year, the Association shall submit a mid-
year report to the Division. The report shall include, at a minimum, the following information:
(i.)
for the period beginning July 1 of the preceding year and ending June 30 of the current year,
a report, for informational purposes only, of each Co-Permittee Member's Discharge and
Estuary TN Loads and the Association's Estuary TN Load; this requirement is waived if the
Association's Estuary TN Load for the previous calendar year was less than 80 percent of
the TN Limitation in that year; and
notification of any further changes in Association membership or TN Allocations to become
effective in the following calendar year.
(d.) Year -End Report. No later than March 31 of each year, the Association shall submit a year-end
report to the Division. The report shall include, at a minimum, the following information for the
previous calendar year:
(i.) for the period from January 1 through December 31 of the preceding year, a report of each
Co-Permittee Member's Discharge and Estuary TN Loads and the Association's Estuary TN
Load;
(ii.) a summary of changes in Association membership; and
(iii.) a summary of all regionalization of discharges, purchases, sales, trades, leases, and other
transactions affecting the TN Allocations of the Association or its Co-Permittee Members.
(e.) Five -Year Report. No later than July 1, 2018, in conjunction with application for renewal of this
permit, the Association shall submit a 5-year report to the Division. The report shall include, at a
minimum, the following information:
(i.) a detailed summary of all membership changes and allowable changes in TN Allocations of
the Association or its Co-Permittee Members occurring during the term of this permit;
(ii.) a description of the Association's TN control strategy during that time;
(iii.) a summary of substantial new measures undertaken during that time to control TN
discharges;
(iv.) a general assessment of progress made; and
(v.) a description of efforts planned for the upcoming permit term, if known.
A.(6.) COMPLIANCE
(a.) In the event that the Association exceeds its Estuary TN Limitation in a given calendar year, the
Association shall make offset payments for that excess TN at a rate consistent with the Nutrient
Offsets Payment rule (15A NCAC 2B .0240) or such other rate as may be adopted by the
Commission. Payment shall be made no later than May 1 of the year following the exceedance
and shall be submitted to:

Permit No. NCC000001
Part I, Page 5 of 5
NCDEQ/ Division of Mitigation Services
Attn: Wetlands Restoration/ In -Lieu Fee Program
1652 Mail Service Center
Raleigh, NC 27699-1652
or other approved mitigation banker, and three copies shall be submitted to:
NCDEQ/ DWR/ Wastewater Branch
Attn: Neuse River Basin Offset Payments
1617 Mail Service Center
Raleigh, NC 27699-1617
(b.) For any calendar year in which the Association exceeds its Estuary TN Limitation, the Association
shall be in violation of this permit, and the Division may take appropriate enforcement action
against the Association.
(c.) For any calendar year in which the Association exceeds its Estuary TN Limitation, any Co-
Permittee Member that exceeds its Estuary TN Limitation shall also be in violation of this permit,
and the Division may take appropriate enforcement action against the Member for such
exceedance.
(d.) For any calendar year, regardless of Association compliance, any Co-Permittee Member that
exceeds an applicable WQBEL for TN shall also be in violation of this permit, and the Division
may take appropriate enforcement action against the Member for such exceedance.
(e.) Submittal of offset payments shall not limit the Division's authority to enforce the terms and
conditions of this permit nor shall it relieve the Association or its Co-Permittee Members of their
responsibility to comply with any other applicable federal, state, or local law, rule, standard,
ordinance, order, judgment, or decree. In determining the amount of any penalty to be assessed
against the Association or its Co-Permittee Members, the Division shall credit the Association or
its Members for any offset payments submitted by each, provided that the Association includes
with the offset payment submittal an accounting of each Member's contribution.
No Co-Permittee Member shall be liable for any other Co-Permittee Member's non-compliance
with this permit.
(f.)
- END OF PART I -

Permit No. NCC000001
Appendix A, Page 1 of 3
APPENDIX A
CO-PERMITTEES, TRANSPORT FACTORS, AND TN ALLOCATIONS - NEUSE RIVER COMPLIANCE ASSOCIATION
Permittee
Permit
Facility
TF
Discharge TN Allocations
Estuary TN Allocations/ Limits
Holdings
Facility
Total
Holdings
Facility Individual
Total WQBELs
1
Apex, Town of
1.1
NC0064050
Apex WRF
50%
40,547
40,547
20,274
20,274
2
Aqua North Carolina, Inc.
2.1
NC0064564
Neuse Colony WWTP
50%
8,447
8,447
4,224
4,224
3
Benson, Town of
3.1
NC0020389
Benson WWTP
50%
33,790
33,070
16,895
16,535
3.1.1 Sale
to Central Johnston County WWTP, NC0030716
-720
-360
4
Cary, Town of
4.1
NC0048879
North Cary WRF
50%
135,158
143,246
67,579
71,623
4.1.1 Connection
4.1.2 Connection
formerly Morrisville WWTP, NC0050041
formerly Morrisville WWTP, NC0050938
4,044
4,044
2,022
2,022
4.2
NC0065102
South Cary WRF
50%
180,211
180,211
90,105
90,105
5
Clayton, Town of
5.1
NC0025453
Little Creek WRF
50%
21,400
22,832
10,700
11,416
5.1.1 Purchase
from UNIFI-Kinston, NC0003760
1,432
716
6
Contentnea Metropolitan
Sewerage District
6.1
NC0032077
Contentnea Sewerage District WWTP
70%
32,100
37,100
22,470
25,970
6.1.1Purchase
from UNIFI-Kinston, NC0003760
5,000
3,500
7
CWS Systems, Inc.
7.1
NC0033111
Fairfield Harbour WWTP
100%
11,263
11,263
11,263
11,263
7.1.1 Lease
from NRCA, former Burlington Industries allocation
0
0
8
Craven County
8.1
NC0089460
Craven County WTP
100%
0
0
0
0
8.1.1 Lease
from NRCA, former Burlington Industries allocation
0
01
9
Duke Energy Progress,
Inc.
9.1
NC0003417
H.F. Lee Energy Complex
70%
0
0
0
0
9.1.1 Lease
from NRCA, former Burlington Industries allocation
0
0 Z
10
E.I. DuPont de Nemours
and Company, Inc.
10.1
NC0003760
E. I. DuPont -Kinston WWTP
70%
35,193
25,493
24,635
17,845
10.1.1 Sale
10.1.2 Sale
10.1.3 Sale
to Town of Clayton WWTP, NC0025453
to Central Johnston County WWTP, NC0030716
to Contentnea MSD WWTP, NC0032077
-2,350
-2,350
-5,000
-1,645
-1,645
-3,500
11
Farmville, Town of
11.1
NC0029572 Farmville WWTP
50%
39,421
42,211
19,711
21,106
11.1.1 Connection formerly Walstonburg WWTP, NC0020362
2,790
1,395
12
Goldsboro, City of
12.1
NC0023949
Goldsboro WRF
70%
189,221
199,822
132,455
139,876
10.1.1 Connection
10.1.2 Connection
10.1.3 Connection
10.1.4 Connection
10.1.5 Connection
formerly Genoa Industrial Park WWTP, NC0030392
formerly Town of Eureka WWTP, NC0048062
formerly Walnut Creek WWTP, NC0039233
formerly Norwayne Jr. HS WWTP, NC0034801
formerly C.B. Aycock HS WWTP, NC0034819
8,088
578
1,618
173
144
5,662
404
1,132
121
101
(Continued next page)

Permit No. NCC000001
Appendix A, Page 2 of 3
APPENDIX A (CONTINUED)
CO-PERMITTEES, TRANSPORT FACTORS, AND TN ALLOCATIONS - NEUSE RIVER COMPLIANCE ASSOCIATION
Permittee
Permit Facility
TF
Discharge TN Allocations
Estuary TN Allocations/ Limits
Holdings
Facility
Total
Holdings
Facility Individual
Total WQBELs
13 Havelock, City of
13.1
NC0021253 Havelock WWTP
100%
21,400
21,400
21,400
21,400
14 Johnston County
14.1
NC0030716 Central Johnston County WWTP
50%
56,203
71,476
28,102
35,738
14.1.1 Connection formerly White Oak P/antation WWTP, NC0060330
5,632
2,816
14.1.2 Agreement formerly Buffalo Creek WWTP, NC0064556
5,632
2,816
14.1.3 Purchase from UNIFI-Kinston, NC0003760
3,290
1,645
14.1.4 Purchase from Town of Benson, NC0020389
720
360
15 Kenly, Town of
15.1
NC0064891 Kenly Regional WWTP
50%
7,096
7,096
3,548
3,548
16 Kinston, City of
16.1
NC0024236 Kinston Regional WRF
70%
50,684
126,711
35,479
88,697
16.1.1 Connection formerly Peachtree WWTP, NC0020541
76,026
53,218
17 La Grange, Town of
17.1
NC0021644 La Grange WWTP
70%
8,447
8,447
5,913
5,913
18 New Bern, City of
18.1
NC0025348 New Bern WWTP
100%
52,937
64,210
52,937
64,210
18.1.1 Connection formerly Zachary Taylor -Hwy 55 Site, NC0066613
5,632
5,632
18.1.2 Connection formerly Neuse Woods Apts., NC0042430
243
243
18.1.3 Connection formerly W. Craven MS, NC0029904
344
344
18.1.4 Connection formerly Neuse River W&SD, NC0070084
2,022
2,022
18.1.5 Connection formerly Craven Co. W&S-Trent River, NC0056545
3,033
3,033
19 Raleigh, City of
19.1
NC0029033 Neuse River WWTP
50%
675,790
687,373
337,895
343,687
19.1.1 Connection formerly P/antation Inn WWTP, NC0027570
506
253
19.1.2 Connection formerly Falls Village WWTP, NC0046230
121
61
19.1.3 Connection formerly Neuse Crossings WWTP, NC0064408
6,066
3,033
19.1.4 Purchase from SGWASA WWTP, NC0026824 (originally from
Bay River MSD, NC0057011, NC0066109)
4,890
2,445
19.2
NC0030759 Smith Creek WWTP
50%
67,579
70,814
33,790
35,407
19.2.1 Connection formerly Jones Dairy Farm WWTP, NC0064149
3,235
1,618
19.3
NC0079316 Little Creek WWTP
50%
20,837
26,660
10,418
13,330
19.3.1 Connection formerly Middlesex WWTP, NC0022363
1,618
809
19.3.2 Connection formerly Indian Creek Overlook, NC0060771
2,265
1,132
19.3.3 Connection formerly Riverwalk MHP, NC0039292
1,031
516
19.3.4 Connection formerly Mill Run MHP, NC0056499
910
455
(Continued next page)

Permit No. NCC000001
Appendix A, Page 3 of 3
APPENDIX A (CONTINUED)
CO-PERMITTEES, TRANSPORT FACTORS, AND TN ALLOCATIONS - NEUSE RIVER COMPLIANCE ASSOCIATION
Permittee
Permit
Facility
TF
Discharge TN Allocations
Estuary TN Allocations/ Limits
Holdings Facility
Total
Holdings
Facility
Total
Individual
WQBELs
20
South Granville Water &
Sewer Authority
20.1
NC0026824
SGWASA WWTP
10%
22,420 22,420
2,242
2,242
21
US MCAS Cherry Point
21.1
NC0003816
Cherry Point WWTP
100%
39,421 39,421
39,421
39,421
22
Wilson, City of
22.1
NC0023906
Wilson WWTP
50%
157,684 157,886
78,842
78,943
22.1.1 Connection
formerly Willow Springs Country Club, NC0031640
202
101
23
NRCA and
Co-Permittee Members
23.1
N/A
[Group allocation held in common]
N/A
24,440
23.1.1 Deeded
by Burlington Industries,
formerly NC0001376
24,4403
23.1.2 Leased
to Progress Energy, NC0003417,
from Burlington Industries allocation
0 2
23.1.3 Leased
01
to CWS Systems, Inc., NC0033111,
from Burlington Industries allocation
23.2
N/A
[Individual allocation held in reserve]
N/A
N/A
23.2.1 Purchase
by Town of
Clayton
from SGWASA, NC0026824
(previously purchased from Bay River MSD)
3,6684
23.2.2 Purchase
by Town of
Clayton
from UNIFI-Kinston, NC0003760
929 4
23.2.1 Held by
SGWASA
formerly active allocation, held by SGWASA
3,6185
Association Estuary TN Limit
1,187,213
Ib/yr I
Total Reserve Estuary Allocation
8,215
Ib/yr
Total Estuary Allocation
1,195,428
Ib/yr
Footnotes:
1. Craven County is currently leasing Total Nitrogen (TN) allocation from the NRCA until the proposed facility is constructed and a determination is made as to the allocation
needed for its discharge. See footnote 3 regarding the TN allocation held by the NRCA.
2. Progress Energy's Lee Steam Plant is allowed a baseline TN load of 3,2601b/yr at its Outfall 001 (2,282 lb/yr at the estuary). Progress leased additional allocation from the
NRCA to ensure coverage for TN discharges from its Rotamix system through 2013. It ceased operation of that system in 2012. The allocations listed in this table and the
amounts to be reported by Progress under this permit pertain strictly to any load in excess of the baseline allowance.
3. In 1999, Burlington Industries deeded its TN allocation (since adjusted to 24,400 lb/yr at the estuary) for use by the Association and its Co-Permittee Members. At present,
the allocation is a group holding assigned to this group permit and is not associated with any individual permit. Unless noted otherwise in this Appendix A, the entire
amount of the allocation is active and is included in the Association Estuary TN Allocation and Limit.
4. Allocation purchased and held in reserve for future use by the co-permittee member.
5. Allocation held in reserve by the co-permittee member; under the Falls Lake nutrient strategy, a more stringent TN limit was set in its individual permit, effective CY2016.

Permit No. NCC000001
Appendix B, Page 1 of 3
APPENDIX B
POINT SOURCE FACILITIES ASSIGNED TOTAL NITROGEN ALLOCATIONS
NEUSE RIVER BASIN
The following is a list of all treatment facilities that, as holders of individual NPDES permits in 1995,
are assigned a Total Nitrogen (TN) allocation pursuant to state rule T15A NCAC 2B .0234, Neuse River
Basin Nutrient Sensitive Waters Management Strategy - Wastewater Discharge Requirements, adopted
December 1997 and revised October 2002.
The rule establishes an aggregate Estuary TN Allocation of 1.64 million pounds TN per year for these
facilities and prescribes how the allocation is to be divided among the individual facilities. The
allocations, individual and aggregate, become effective with calendar year 2003.
The Total Maximum Daily Load for Total Nitrogen to the Neuse River Estuary, North Carolina, approved by
the USEPA Region 4 in July 1999, also concludes that this aggregate allocation is the maximum
allowable contribution from point source dischargers to the Neuse River estuary.
NPDES
Permit No.
Permittee
Facility
Subbasin
Transport
Factor
1.
NC0037869
Arbor Hills MHP - 1
Arbor Hills Mobile Home Park
30401
10%
2.
NC0066109
Bay River MSD
Bayboro WWTP
30410
100%
3.
NC0057011
Bay River MSD
Oriental WWTP
30410
100%
4.
NC0058785
Bible Baptist Church
Bible Baptist Church WWTP
30401
10%
5.
NC0027570
Bobby L. Murray
Plantation Inn WWTP
30402
50%
6.
NC0001376
Burlington Industries
Wake Plant WWTP
30402
50%
7.
NC0051322
Carolina Water Service, Inc. of NC
Ashley Hill WWTP
30402
50%
8.
NC0056618
Carolina Water Service, Inc. of NC
Carolina Pines WWTP
30410
100%
9.
NC0062219
Carolina Water Service, Inc. of NC
Kings Grant Subdivision WWTP
30402
50%
10.
NC0033111
Carolina Water Service, Inc. of NC
NE Craven WWTP
30410
100%
11.
NC0064378
Carolina Water Service, Inc. of NC
Willowbrook WWTP
30402
50%
12.
NC0023841
City of Durham
North Durham WRF
30401
10%
13.
NC0023949
City of Goldsboro
Goldsboro WWTP
30405
70%
14.
NC0021253
City of Havelock
Havelock WWTP
30410
100%
15.
NC0024236
City of Kinston
Northside WWTP
30405
70%
16.
NC0020541
City of Kinston
Peachtree WWTP
30405
70%
17.
NC0025348
City of New Bern
New Bern WWTP
30410
100%
18.
NC0029033
City of Raleigh
Neuse River WWTP
30402
50%
19.
NC0023906
City of Wilson
Wilson WWTP
30407
50%
20.
NC0032077
Contentnea Metropolitan Sewerage Dist.
Contentnea Sewerage District WWTP
30407
70%
21.
NC0029904
Craven County Schools
West Craven Middle School WWTP
30408
100%
22.
NC0070084
Craven County Water & Sewer
Stately Pines WWTP
30410
100%
23.
NC0056545
Craven County Water & Sewer
Trent River WWTP
30410
100%
24.
NC0065706
Crosby Utilities
Crosby Utilities/Cottonwood
30402
50%
25.
NC0046230
Crosby Water and Sewer, Inc.
Falls Village WWTP
30402
50%
26.
NC0022853
Durham Products
Eno Sewage Facility
30401
10%
27.
NC0003760
E. I. Dupont de Nemours & Company, Inc.
Kinston Plant
30405
70%
28.
NC0066150
FMRK, Inc.
Brighton Forest WWTP
30403
50%
29.
NC0024520
G & S Associates
Days Inn - Durham
30401
10%
30.
NC0043389
Gorman Baptist Church
Gorman BC WWTP
30401
10%
31.
NC0040606
Heater Utilities, Inc.
Barclay Downs WWTP
30402
50%
32.
NC0060577
Heater Utilities, Inc.
Beachwood WWTP
30402
50%

Permit No. NCC000001
Appendix B, Page 2 of 3
NPDES
Permit No.
Permittee
Facility
Subbasin
Transport
Factor
33.
NC0062740
Heater Utilities, Inc.
Briarwood Farms WWTP
30403
50%
34.
NC0062715
Heater Utilities, Inc.
Crooked Creek WWTP
30403
50%
35.
NC0056391
Heater Utilities, Inc.
Cross Creek Mobile Estates WWTP
30402
50%
36.
NC0049662
Heater Utilities, Inc.
Hawthorne Subdivision WWTP
30401
10%
37.
NC0058505
Heater Utilities, Inc.
Mallard Crossing WWTP
30402
50%
38.
NC0064564
Heater Utilities, Inc.
Neuse Colony WWTP
30402
50%
39.
NC0063614
Heater Utilities, Inc.
Wildwood Green WWTP
30401
10%
40.
NC0060771
Indian Creek Overlook
Indian Creek Overlook
30402
50%
41.
NC0063746
Ira D Lee & Associates
Deerchase WWTP
30402
50%
42.
NC0073318
Ira D Lee & Associates
Whippoorwill Valley WWTP
30402
50%
43.
NC0030716
Johnston County
Central Johnston County WWTP
30402
50%
44.
NC0060330
Johnston County
White Oak Plantation WWTP
30402
50%
45.
NC0038938
Johnston County Board of Education
Corinth -Holder Elementary & Middle School
30406
50%
46.
NC0064149
Jones Dairy Farm Utilities
Jones Dairy Farm WWTP
30402
50%
47.
NC0040266
Knightdale MHP Limited Partnership
Knightdale MHP Limited Partnership
30402
50%
48.
NC0059099
Lake Ridge Aero Park
Lake Ridge Aero Park
30401
10%
49.
NC0032573
Lenoir County Public Schools
Moss Hill Elementary School WWTP
30405
70%
50.
NC0032565
Lenoir County Public Schools
North Lenoir High School WWTP
30407
50%
51.
NC0032557
Lenoir County Public Schools
South Lenoir High School WWTP
30407
50%
52.
NC0061492
Maury Sanitary Land District
Maury Sanitary Land District WWTP
30407
50%
53.
NC0049034
Mount Auburn Training Center
Mount Auburn Training Center
30402
50%
54.
NC0043001
Mt. Sylvan United Methodist Church
Mt. Sylvan UMC WWTP
30401
10%
55.
NC0037915
Nash/Rocky Mount Schools
Southern Nash High School
30407
50%
56.
NC0035181
NC Center For Mature Adults
NC Center For Mature Adults
30403
50%
57.
NC0026824
NC DHHS
Butner WWTP
30401
10%
58.
NC0042340
Neuse Woods Apartments
Neuse Woods Apartments
30410
100%
59.
NC0064246
Pace Mobile Home Park
Pace Mobile Home Park
30402
50%
60.
NC0036471
Person County Schools
Helena Elementary School WWTP
30401
10%
61.
NC0001881
Phillips Plating Company
Phillips Plating Company
30410
100%
62.
NC0060526
Pope Industrial Park II Ltd
Pope Industrial Park II Ltd
30402
50%
63.
NC0051071
Redwood Partners LLC
Redwood Academy WWTP
30401
10%
64.
NC0049042
Riley Hill Baptist Church Inc
Riley Hill Baptist Church Inc
30406
50%
65.
NC0064556
River Dell Utilities, Inc.
Buffalo Creek WWTP
30406
50%
66.
NC0056278
River Mill Homeowners Association, Inc.
River Mill WWTP
30402
50%
67.
NC0038784
Riverview Mobile Home Park
Riverview Mobile Home Park
30402
50%
68.
NC0030724
Southside MHP
Southside MHP WWTP
30403
50%
69.
NC0056731
The Chesson Group
Grande Oak Subdivision WWTP
30401
10%
70.
NC0064050
Town of Apex
Middle Creek WWTP
30403
50%
71.
NC0020389
Town of Benson
Benson WWTP
30404
50%
72.
NC0074837
Town of Bridgeton
Bridgeton WWTP
30410
100%
73.
NC0048879
Town of Cary
North WWTP
30402
50%
74.
NC0065102
Town of Cary
South WWTP
30403
50%
75.
NC0025453
Town of Clayton
Little Creek WWTP
30402
50%
76.
NC0048062
Town of Eureka
Eureka Town- WWTP
30407
50%
77.
NC0029572
Town of Farmville
Farmville WWTP
30407
50%
78.
NC0066516
Town of Fuquay-Varina
Terrible Creek WWTP
30403
50%
79.
NC0026433
Town of Hillsborough
Hillsborough WWTP
30401
10%
80.
NC0025712
Town of Hookerton
Hookerton WWTP
30407
50%
81.
NC0064891
Town of Kenly
Kenly Regional WWTP
30406
50%

Permit No. NCC000001
Appendix B, Page 3 of 3
NPDES
Permit No.
Permittee
Facility
Subbasin
Transport
Factor
82.
NC0021644
Town of La Grange
La Grange WWTP
30405 70%
83.
NC0022363
Town of Middlesex
Middlesex WWTP
30407
50%
84.
NC0050938
Town of Morrisville
Morrisville WTP
30402
50%
85.
NC0050041
Town of Morrisville
Morrisville WWTP
30402
50%
86.
NC0026662
Town of Princeton
Princeton WWTP
30406
50%
87.
NC0030406
Town of River Bend
River Bend WWTP
30411
100%
88.
NC0020842
Town of Snow Hill
Snow Hill WWTP
30407
50%
89.
NC0057606
Town of Stantonsburg
Stantonsburg WWTP
30407
50%
90.
NC0021342
Town of Trenton
Trenton WWTP
30411
100%
91.
NC0031828
Town of Vanceboro
Vanceboro WWTP
30409
100%
92.
NC0030759
Town of Wake Forest
Wake Forest WWTP
30402
50%
93.
NC0020362
Town of Walstonburg
Walstonburg WWTP
30407
50%
94.
NC0079316
Town of Zebulon
Little Creek WWTP
30407
50%
95.
NC0065714
Tradewinds Homeowners Association, Inc.
Tradewinds WWTP
30402
50%
96.
NC0056499
Uniprop, Inc.
Mill Run Mobile Home Park
30402
50%
97.
NC0039292
Uniprop, Inc.
Riverwalk Mobile Home Park
30402
50%
98.
NC0003816
US MCAS Cherry Point
Cherry Point WWTP
30410
100%
99.
NC0061638
Utilities Inc
Amherst WWTP
30403
50%
100.
NC0039233
Village of Walnut Creek
Walnut Creek WWTP
30405
70%
101.
NC0025631
Wake Technical Institute
Wake Tech WWTP
30403
50%
102.
NC0030392
Wayne County
Genoa Industrial Park WWTP
30405
70%
103.
NC0034819
Wayne County Board of Education
Charles B. Aycock High School
30407
50%
104.
NC0034801
Wayne County Board of Education
Norwayne Junior High School
30407
50%
105.
NC0003191
Weyerhaeuser Company
New Bern Mill
30408
100%
106.
NC0064408
Whitewood Prop Inc
Neuse Crossing WWTP
30402
50%
107.
NC0031640
Willow Springs Country Club
Willow Springs CC WWTP
30407
50%
108.
NC0081752
Willowhaven Country Club
Willowhaven CC WWTP
30401
10%
109.
NC0066613
Zachary Taylor
Hwy 55 Site WWTP
30410 100%

Parts II & III
Page 1 of 9
Permit No. NCC000001
PART II
STANDARD CONDITIONS FOR NPDES PERMITS
SECTION A - APPLICABILITY OF PARTS II AND III
Parts II and III of this permit contain standard conditions that apply specifically to individual permittees
that own or operate a treatment facility. These (or similar) conditions are routinely found in North
Carolina's NPDES wastewater permits, including those of the Neuse River Compliance Association's co-
permittee members. The conditions do not necessarily apply to the Association or its members within the
context of this group permit. The group permit includes those standard conditions that apply here at least in
part. For the purposes of determining compliance with this permit, these conditions shall be read with the
following understanding:
a. The Neuse River Compliance Association serves as a governing body for its Members. It neither owns
nor operates treatment facilities. Consequently, the standard conditions in Parts II and III of this permit
which by their terms or meaning regulate a permittee that owns or operates a treatment facility, or
which are inconsistent with the Special Conditions in Part I of this permit, shall neither be applicable to
nor enforceable against the Association.
b. Each of the Co-Permittee Members governed by this Association permit owns or operates one or more
treatment facilities. Each holds an individual NPDES permit for each facility and remains subject to the
standard conditions in its permit(s). Consequently, the standard conditions in this Association permit
shall neither be applicable to nor enforceable against the individual Co-Permittee Members under this
group permit unless such is clearly consistent with the construction of the permit.
c. Wherever a standard condition in this Association permit is by its terms or meaning applicable to the
Association or to the membership in its entirety, and it refers to "the permittee," it shall be construed to
mean the Association and its Co-Permittee Members.
SECTION B - DEFINITIONS
1. Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33
USC 1251, et. seq.
2. DWR or "the Division"
The Division of Water Resources, Department of Environment Quality.
3. EMC
The North Carolina Environmental Management Commission.
4. EPA
The United States Environmental Protection Agency.
5. Permit Issuing Authority
The Director of the Division of Water Resources.
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Parts II & III
Page 2 of 9
Permit No. NCC000001
SECTION C - GENERAL CONDITIONS
1. Duty to Comply
The Permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a
violation of the CWA and is grounds for enforcement action; for permit termination, revocation and
reissuance, or modification; or denial of a permit renewal application [40 CFR 122.41].
a. The Permittee shall comply with effluent standards or prohibitions established under section 307(a)
of the CWA for toxic pollutants and with standards for sewage sludge use or disposal established
under section 405(d) of the CWA within the time provided in the regulations that establish these
standards or prohibitions or standards for sewage sludge use or disposal, even if the permit has not
yet been modified to incorporate the requirement.
b. The CWA provides that any person who violates section[s] 301, 302, 306, 307, 308, 318 or 405 of the
Act, or any permit condition or limitation implementing any such sections in a permit issued under
section 402, or any requirement imposed in a pretreatment program approved under sections
402(a)(3) or 402(b)(8) of the Act, is subject to a civil penalty not to exceed $37,500 per day for each
violation. [33 USC 1319(d) and 40 CFR 122.41(a)(2)]
c. The CWA provides that any person who negligently violates sections 301, 302, 306, 307, 308, 318, or
405 of the Act, or any condition or limitation implementing any of such sections in a permit issued
under section 402 of the Act, or any requirement imposed in a pretreatment program approved
under section 402(a)(3) or 402(b)(8) of the Act, is subject to criminal penalties of $2,500 to $25,000 per
day of violation, or imprisonment of not more than 1 year, or both. In the case of a second or
subsequent conviction for a negligent violation, a person shall be subject to criminal penalties of not
more than $50,000 per day of violation, or by imprisonment of not more than 2 years, or both. [33
USC 1319(c)(1) and 40 CFR 122.41(a)(2)]
d. Any person who knowingly violates such sections, or such conditions or limitations is subject to
criminal penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3
years, or both. In the case of a second or subsequent conviction for a knowing violation, a person
shall be subject to criminal penalties of not more than $100,000 per day of violation, or imprisonment
of not more than 6 years, or both. [33 USC 1319(c)(2) and 40 CFR 122.41(a)(2)]
e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or any
permit condition or limitation implementing any of such sections in a permit issued under section
402 of the Act, and who knows at that time that he thereby places another person in imminent
danger of death or serious bodily injury, shall, upon conviction, be subject to a fine of not more than
$250,000 or imprisonment of not more than 15 years, or both. In the case of a second or subsequent
conviction for a knowing endangerment violation, a person shall be subject to a fine of not more
than $500,000 or by imprisonment of not more than 30 years, or both. An organization, as defined in
section 309(c)(3)(B)(iii) of the CWA, shall, upon conviction of violating the imminent danger
provision, be subject to a fine of not more than $1,000,000 and can be fined up to $2,000,000 for
second or subsequent convictions. [40 CFR 122.41(a)(2)]
f. Under state law, a civil penalty of not more than $25,000 per violation may be assessed against any
person who violates or fails to act in accordance with the terms, conditions, or requirements of a
permit. [North Carolina General Statutes § 143-215.6A]
Any person may be assessed an administrative penalty by the Administrator for violating section
301, 302, 306, 307, 308, 318 or 405 of this Act, or any permit condition or limitation implementing any
of such sections in a permit issued under section 402 of this Act. Administrative penalties for Class I
violations are not to exceed $16,000 per violation, with the maximum amount of any Class I penalty
assessed not to exceed $37,500. Penalties for Class II violations are not to exceed $16,000 per day for
each day during which the violation continues, with the maximum amount of any Class II penalty
not to exceed $177,500. [33 USC 1319(g)(2) and 40 CFR 122.41(a)(3)]
g.
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Parts II&III
Page 3 of 9
Permit No. NCC000001
2. Duty to Mitigate
The Permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or
disposal in violation of this permit with a reasonable likelihood of adversely affecting human health or
the environment [40 CFR 122.41(d)].
3. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part II.C.4), "Upsets" (Part II.C.5) and "Power
Failures" (Part II.C.7), nothing in this permit shall be construed to relieve the Permittee from any
responsibilities, liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3,143-215.6 or
Section 309 of the Federal Act, 33 USC 1319. Furthermore, the Permittee is responsible for consequential
damages, such as fish kills, even though the responsibility for effective compliance may be temporarily
suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the
Permittee from any responsibilities, liabilities, or penalties to which the Permittee is or may be subject to
under NCGS 143-215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321. Furthermore, the
Permittee is responsible for consequential damages, such as fish kills, even though the responsibility for
effective compliance may be temporarily suspended.
5. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or
any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal
rights, nor any infringement of Federal, State or local laws or regulations [40 CFR 122.41(g)].
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical
structures or facilities or the undertaking of any work in any navigable waters.
7. Severability
The provisions of this permit are severable. If any provision of this permit, or the application of any
provision of this permit to any circumstances, is held invalid, the application of such provision to other
circumstances, and the remainder of this permit, shall not be affected thereby [NCGS 150B-23].
8. Duty to Provide Information
The Permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information
which the Permit Issuing Authority may request to determine whether cause exists for modifying,
revoking and reissuing, or terminating this permit or to determine compliance with this permit. The
Permittee shall also furnish to the Permit Issuing Authority upon request, copies of records required by
this permit [40 CFR 122.41(h)].
9. Duty to Reapply
If the Permittee wishes to continue an activity regulated by this permit after the expiration date of this
permit, the Permittee must apply for and obtain a new permit [40 CFR 122.41(b)].
10. Expiration of Permit
The Permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the Permittee shall submit such information,
forms, and fees as are required by the agency authorized to issue permits no later than 180 days prior to
the expiration date unless permission for a later date has been granted by the Director. (The Director
shall not grant permission for applications to be submitted later than the expiration date of the existing
permit.) [40 CFR 122.21(d)] Any Permittee that has not requested renewal at least 180 days prior to
expiration, or any Permittee that does not have a permit after the expiration and has not requested
renewal at least 180 days prior to expiration, will subject the Permittee to enforcement procedures as
provided in NCGS 143-215.6 and 33 USC 1251 et. seq.
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Parts II & III
Page 4 of 9
Permit No. NCC000001
11. Signatory Requirements
All applications, reports, or information submitted to the Permit Issuing Authority shall be signed and
certified [40 CFR 122.41(k)].
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a
responsible corporate officer means: (a) a president, secretary, treasurer or vice president of the
corporation in charge of a principal business function, or any other person who performs similar
policy or decision making functions for the corporation, or (b) the manager of one or more
manufacturing, production, or operating facilities, provided, the manager is authorized to make
management decisions which govern the operation of the regulated facility including having the
explicit or implicit duty of making major capital investment recommendations, and initiating
and directing other comprehensive measures to assure long term environmental compliance
with environmental laws and regulations; the manager can ensure that the necessary systems are
established or actions taken to gather complete and accurate information for permit application
requirements; and where authority to sign documents has been assigned or delegated to the
manager in accordance with corporate procedures .
(2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a principal executive officer
or ranking elected official [40 CFR 122.22].
b. All reports required by the permit and other information requested by the Permit Issuing Authority
shall be signed by a person described in paragraph a. above or by a duly authorized representative
of that person. A person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant manager,
operator of a well or well field, superintendent, a position of equivalent responsibility, or an
individual or position having overall responsibility for environmental matters for the company.
(A duly authorized representative may thus be either a named individual or any individual
occupying a named position.); and
(3) The written authorization is submitted to the Permit Issuing Authority [40 CFR 122.22]
c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer
accurate because a different individual or position has responsibility for the overall operation of the
facility, a new authorization satisfying the requirements of paragraph (b) of this section must be
submitted to the Director prior to or together with any reports, information, or applications to be
signed by an authorized representative [40 CFR 122.22]
d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make
the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL
BE ACCEI'l'ED:
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or
those persons directly responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fines and imprisonment for knowing violations."
12. Permit Actions •
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by
the Permittee for a permit modification, revocation and reissuance, or termination, or a notification of
planned changes or anticipated noncompliance does not stay any permit condition [40 CFR 122.41(0].
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13. Permit Modification, Revocation and Reissuance, or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and
modifying the permit, revoking and reissuing the permit, or terminating the permit as allowed by the
laws, rules, and regulations contained in Title 40, Code of Federal Regulations, Parts 122 and 123; Title
15A of the North Carolina Administrative Code, Subchapter 02H .0100; and North Carolina General
Statute 143.215.1 et. al.
14. Annual Administering and Compliance Monitoring Fee Requirements
The Permittee must pay the annual administering and compliance monitoring fee within thirty days
after being billed by the Division. Failure to pay the fee in a timely manner in accordance with 15A
NCAC 02H .0105(b)(2) may cause this Division to initiate action to revoke the permit.
SECTION D - MONITORING AND RECORDS
1. Representative Sampling
Samples collected and measurements taken, as required herein, shall be representative of the permitted
discharge. Samples collected at a frequency less than daily shall be taken on a day and time that is
representative of the discharge for the period the sample represents. All samples shall be taken at the
monitoring points specified in this permit and, unless otherwise specified, before the effluent joins or is
diluted by any other wastestream, body of water, or substance. Monitoring points shall not be changed
without notification to and the approval of the Permit Issuing Authority [40 CFR 122.41(j)].
2. Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each month and
reported on a monthly Discharge Monitoring Report (DMR) Form (MR 1,1.1, 2, 3) or alternative forms
approved by the Director, postmarked no later than the last calendar day of the month following the
completed reporting period.
The first DMR is due on the last day of the month following the issuance of the permit or in the case of a
new facility, on the last day of the month following the commencement of discharge. Duplicate signed
copies of these, and all other reports required herein, shall be submitted to the following address:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices shall
be selected and used to ensure the accuracy and reliability of measurements of the volume of monitored
discharges. The devices shall be installed, calibrated and maintained to ensure that the accuracy of the
measurements is consistent with the accepted capability of that type of device. Devices selected shall be
capable of measuring flows with a maximum deviation of less than 10% from the true discharge rates
throughout the range of expected discharge volumes. Flow measurement devices shall be accurately
calibrated at a minimum of once per year and maintained to ensure that the accuracy of the
measurements is consistent with the accepted capability of that type of device. The Director shall
approve the flow measurement device and monitoring location prior to installation.
Once -through condenser cooling water flow monitored by pump logs, or pump hour meters as specified
in Part I of this permit and based on the manufacturer's pump curves shall not be subject to this
requirement.
4. Test Procedures
Laboratories used for sample analysis must be certified by the Division. Permittees should contact the
Division's Laboratory Certification Section (919 733-3908 or
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https:/ / deq.nc.gov/ about/ divisions/ water -resources/ water -resources -data/ water-sciences-home-
page/laboratory-certification-branch) for information regarding laboratory certifications.
Facilities whose personnel are conducting testing of field -certified parameters only must hold the
appropriate field parameter laboratory certifications.
Test procedures for the analysis of pollutants shall conform to the EMC regulations (published pursuant
to NCGS 143-215.63 et. seq.), the Water and Air Quality Reporting Acts, and to regulations published
pursuant to Section 304(g), 33 USC 1314, of the CWA (as amended), and 40 CFR 136; or in the case of
sludge use or disposal, approved under 40 CFR 136, unless otherwise specified in 40 CFR 503, unless
other test procedures have been specified in this permit [40 CFR 122.41].
To meet the intent of the monitoring required by this permit, all test procedures must produce minimum
detection and reporting levels that are below the permit discharge requirements and all data generated
must be reported down to the minimum detection or lower reporting level of the procedure. If no
approved methods are determined capable of achieving minimum detection and reporting levels below
permit discharge requirements, then the most sensitive (method with the lowest possible detection and
reporting level) approved method must be used.
5. Penalties for Tampering
The CWA provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any
monitoring device or method required to be maintained under this permit shall, upon conviction, be
punished by a fine of not more than $10,000 per violation, or by imprisonment for not more than two
years per violation, or by both. If a conviction of a person is for a violation committed after a first
conviction of such person under this paragraph, punishment is a fine of not more than $20,000 per day
of violation, or by imprisonment of not more than 4 years, or both [40 CFR 122.41].
6. Records Retention
Except for records of monitoring information required by this permit related to the Permittee's sewage
sludge use and disposal activities, which shall be retained for a period of at least five years (or longer as
required by 40 CFR 503), the Permittee shall retain records of all monitoring information, including:
➢ all calibration and maintenance records
➢ all original strip chart recordings for continuous monitoring instrumentation
➢ copies of all reports required by this permit
> copies of all data used to complete the application for this permit
These records or copies shall be maintained for a period of at least 3 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time
[40 CFR 122.41].
7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the Permittee shall
record the following information [40 CFR 122.41]:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
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8. Inspection and Entry
The Permittee shall allow the Director, or an authorized representative (including an authorized
contractor acting as a representative of the Director), upon the presentation of credentials and other
documents as may be required by law, to;
a. Enter, at reasonable times, upon the Permittee's premises where a regulated facility or activity is
located or conducted, or where records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of
this permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment),
practices, or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as
otherwise authorized by the CWA, any substances or parameters at any location [40 CFR 122.41(i)].
SECTION F - REPORTING REQUIREMENTS
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this permit. The
discharge of any pollutant identified in this permit more frequently than or at a level in excess of that
authorized shall constitute a violation of the permit.
2. Planned Changes
The Permittee shall give notice to the Director as soon as possible of any planned physical alterations or
additions to the permitted facility [40 CFR 122.41(1)]. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for new sources at 40
CFR 122.29(b); or
b. The alteration or addition could significantly change the nature or increase the quantity of pollutants
discharged. This notification applies to pollutants subject neither to effluent limitations in the
permit, nor to notification requirements under 40 CFR 122.42(a)(1); or
c. The alteration or addition results in a significant change in the Permittee's sludge use or disposal
practices, and such alteration, addition or change may justify the application of permit conditions
that are different from or absent in the existing permit, including notification of additional use or
disposal sites not reported during the permit application process or not reported pursuant to an
approved land application plan.
3. Anticipated Noncompliance
The Permittee shall give advance notice to the Director of any planned changes to the permitted facility
or other activities that might result in noncompliance with the permit [40 CFR 122.41(1)(2)].
4. Transfers
This permit is not transferable to any person without prior written notice to and approval from the
Director in accordance with 40 CFR 122.61. The Director may condition approval in accordance with
NCGS 143-215.1, in particular NCGS 143-215.1(b)(4)b.2., and may require modification or revocation and
reissuance of the permit, or a minor modification, to identify the new permittee and incorporate such
other requirements as may be necessary under the CWA [40 CFR 122.41(1)(3),122.61] or state statute.
5. Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit [40 CFR
122.41(1)(4)].
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part II.D.2) or
forms provided by the Director for reporting results of monitoring of sludge use or disposal
practices.
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b. If the Permittee monitors any pollutant more frequently than required by this permit using test
procedures approved under 40 CFR Part 136 and at a sampling location specified in this permit or
other appropriate instrument governing the discharge, the results of such monitoring shall be
included in the calculation and reporting of the data submitted on the DMR.
6. Twenty-four Hour Reporting
a. The Permittee shall report to the Director or the appropriate Regional Office any noncompliance that
potentially threatens public health or the environment. Any information shall be provided orally
within 24 hours from the time the Permittee became aware of the circumstances. A written
submission shall also be provided within 5 days of the time the Permittee becomes aware of the
circumstances. The written submission shall contain a description of the noncompliance, and its
cause; the period of noncompliance, including exact dates and times, and if the noncompliance has
not been corrected, the anticipated time it is expected to continue; and steps taken or planned to
reduce, eliminate, and prevent reoccurrence of the noncompliance [40 CFR 122.41(1)(6)].
b. The Director may waive the written report on a case -by -case basis for reports under this section if
the oral report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency
Response personnel at [phone], [phone] or [phone].
7. Other Noncompliance
The Permittee shall report all instances of noncompliance not reported under Part II.E.5 and 6. of this
permit at the time monitoring reports are submitted. The reports shall contain the information listed in
Part II.E.6. of this permit [40 CFR 122.41(1)(7)].
8. Other Information
Where the Permittee becomes aware that it failed to submit any relevant facts in a permit application, or
submitted incorrect information in a permit application or in any report to the Director, it shall promptly
submit such facts or information [40 CFR 122.41(1)(8)].
9. Noncompliance Notification
The Permittee shall report by telephone to either the central office or the appropriate regional office of
the Division as soon as possible, but in no case more than 24 hours or on the next working day following
the occurrence or first knowledge of the occurrence of any of the following:
a. Any occurrence at the water pollution control facility which results in the discharge of significant
amounts of wastes which are abnormal in quantity or characteristic, such as the dumping of the
contents of a sludge digester; the known passage of a slug of hazardous substance through the
facility; or any other unusual circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of
adequate wastewater treatment such as mechanical or electrical failures of pumps, aerators,
compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass without
treatment of all or any portion of the influent to such station or facility.
Persons reporting such occurrences by telephone shall also file a written report within 5 days following
first knowledge of the occurrence. Also see reporting requirements for municipalities in Part IV.C.2.c. of
this permit.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3 (a)(2) or Section 308 of the Federal
Act, 33 USC 1318, all reports prepared in accordance with the terms shall be available for public
inspection at the offices of the Division. As required by the Act, effluent data shall not be considered
confidential. Knowingly making any false statement on any such report may result in the imposition of
criminal penalties as provided for in NCGS 143-215.1(b)(2) or in Section 309 of the Federal Act.
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11. Penalties for Falsification of Reports
The CWA provides that any person who knowingly makes any false statement, representation, or
certification in any record or other document submitted or required to be maintained under this permit,
including monitoring reports or reports of compliance or noncompliance shall, upon conviction, be
punished by a fine of not more than $25,000 per violation, or by imprisonment for not more than two
years per violation, or by both [40 CFR 122.41].
12. Annual Performance Reports
Permittees who own or operate facilities that collect or treat municipal or domestic waste shall provide
an annual report to the Permit Issuing Authority and to the users/customers served by the Permittee
(NCGS 143-215.1C). The report shall summarize the performance of the collection or treatment system,
as well as the extent to which the facility was compliant with applicable Federal or State laws,
regulations and rules pertaining to water quality. The report shall be provided no later than sixty days
after the end of the calendar or fiscal year, depending upon which annual period is used for evaluation.
The report shall be sent to:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
PART III
OTHER REQUIREMENTS
SECTION A - CONSTRUCTION
a. The Permittee shall not commence construction of wastewater treatment facilities, nor add to the plant's
treatment capacity, nor change the treatment process(es) utilized at the treatment plant unless (1) the
Division has issued an Authorization to Construct (ATC) permit or (2) the Permittee is exempted from
such ATC permit requirements under Item b. of this Section.
b. In accordance with NCGS 143-215.1(a5) [SL 2011-394], no permit shall be required to enter into a
contract for the construction, installation, or alteration of any treatment work or disposal system or to
construct, install, or alter any treatment works or disposal system within the State when the system's or
work's principle function is to conduct, treat, equalize, neutralize, stabilize, recycle, or dispose of
industrial waste or sewage from an industrial facility and the discharge of the industrial waste or
sewage is authorized under a permit issued for the discharge of the industrial waste or sewage into the
waters of the State. Notwithstanding the above, the permit issued for the discharge may be modified if
required by federal regulation.
c. Issuance of an ATC will not occur until Final Plans and Specifications for the proposed construction
have been submitted by the Permittee and approved by the Division.
-END OFPARTSII&Ill-
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NORTH CAROLINA
Environmental Quality
Fact Sheet - NPDES Permit
Neuse River Compliance Association
NPDES No. NCC000001
CY2019-23 Renewal - FINAL
December 12, 2018
PERMIT ACTION
On June 28, 2018, the Neuse River Compliance Association and its co-permittee members applied
for renewal of the NPDES group permit governing their discharge of Total Nitrogen to the Neuse
River and its tributaries.
On or about October 19, 2018, the Division published a notice of its tentative determination to re-
issue the permit without modification. No comments were received. The Division issued the permit
as proposed, with an effective date of January 1, 2019.
INTRODUCTION
The Neuse River basin was classified as Nutrient Sensitive Waters (NSW) in 1988 due to long-term
nutrient impacts from point, nonpoint, and natural sources of pollution on the river's estuary. In
1994, the Division added the basin to the state's 303(d) list of impaired waters due to exceedance of
the chlorophyll a standard at the estuary.
In December 1997, the Environmental Management Commission adopted the Neuse River Basin
Nutrient Sensitive Waters (NSW) Management Strategy, a rules package designed to address these
nutrient impacts and restore water quality in the basin. The Strategy required that Total Nitrogen
(TN) loads to the estuary (1995 baseline) be reduced by 30 percent by the year 2003.
The Division developed a phased Total Nitrogen TMDL for the basin, based upon the NSW
Management Strategy. The USEPA approved the TMDL in 1999 (Phase I) and 2002 (Phase II).
Subsequent 303(d) lists and Integrated Reports have reflected that the TMDLs are being
implemented.
One portion of the NSW Management Strategy, the Wastewater Discharge Requirements rule
(T15A NCAC 2B .0234), establishes specific nutrient control requirements for the point source
dischargers in the basin.
• The rule sets forth a system of Total Nitrogen allocations to achieve the stated 30 percent
reduction in point source loads to the estuary. Toward this end, it:
• sets a wasteload allocation (WLA) of 1.64 million pounds TN per year (at the estuary) for
all point source dischargers in the basin.
• further divides the WLA among the existing dischargers.
• requires that large facilities (those with permitted flows equal to or greater than 500,000
gallons per day) meet TN limits based on their individual TN allocations, beginning in
2003.
• establishes requirements for new and expanding dischargers
• prescribes how allocations will be handled when permitted facilities consolidate
(regionalize) their wastewater discharges.

Neuse River Compliance Association FACT SHEET
NPDES No. NCC000001 FINAL NPDES PERMIT
• The rule also prescribes Total Phosphorus limits for the most significant dischargers in the
basin.
To provide the dischargers some flexibility in meeting their nitrogen control requirements, the rule
provides that interested dischargers can work collectively to achieve nitrogen reductions. Under
this approach, the dischargers form a group compliance association and obtain a group NPDES
permit. The group permit establishes a group TN limit based on the members' combined TN
allocations. The group limit replaces the TN limits in their individual permits. Otherwise, the group
permit does not affect requirements in the individual permits.
The subject permit is a group compliance permit as described above. It first became effective
January 1, 2003, and is the only such permit to be developed under the Strategy's Wastewater
Discharge rule.
PERMIT OVERVIEW
The Neuse River Compliance Association ("NRCA," or the "Association") is a not -for -profit
corporation established in North Carolina in 2002. The purpose of the Association is to function as a
"group compliance association" as provided in the Wastewater Discharge rule.
Co-Permittees
The Association's members include both public and private entities, all of which discharge treated
wastewater in the Neuse River basin under existing individual NPDES permits.
The Association and each of its members are co-permittees under the group permit. In general, the
Association serves as the contact between the Division and its co-permittee members in matters
pertaining to this permit.
Scope of the Permit
The group compliance permit governs the combined discharge of Total Nitrogen from the co-
permittees to the estuary. Requirements in this permit supplement those in the co-permittee
members' individual NPDES permits but do not replace the requirements in the individual permits
except where specifically stated.
Each member's individual NPDES permit remains in effect and continues to govern the other
parameters of concern for that discharge.
Organization and Content of the Permit
The Division developed effluent limitations and other special conditions for the original (2002)
group permit based on the Neuse River Basin Nutrient Management Strategy, the approved TN
TMDLs, and extensive deliberations with the USEPA Region 4 and with the affected dischargers.
As with individual NPDES permits, the group permit contains Special Conditions governing
wastewater controls (Part I). However, the content of the group permit is unique:
• Definitions of key terms
• Ground rules and general requirements pertaining to the group compliance approach
• Explanation of group and individual TN limits
• Special reporting requirements
• Compliance standards and procedures in case of limits violations
The selection of standard and general conditions in the permit (Parts II & III) is also tailored to the
specific needs of the group permit. Many do not actually apply to the Association or its co-

Neuse River Compliance Association FACT SHEET
NPDES No. NCC000001 FINAL NPDES PERMIT
permittee members although they are found in the members' individual permits and do apply
there; they are included in the group permit merely for emphasis or a sense of completeness.
Appendix A of the permit contains the definitive list of (1) Co-Permittee Members in the
Association, (2) discharge and equivalent estuary TN allocations for each member, and (3) transport
factors for each. These values are derived from the allocations assigned in the Wastewater
Discharge rule.
The permit establishes TN limits for the Association and for the individual co-permittee members.
Individual TN limits equal the members' individual, active allocations, and the Association's
Estuary TN Limitation equals the sum total of the members' active allocations. All TN limits in
Appendix A are annual mass limits, are expressed in terms of estuary ('delivered') TN, and apply
on a calendar -year basis. The appendix also notes which allocations (if any) are held in 'reserve'
status and are, therefore, not included in the group TN limit.
The Association is subject to its Estuary TN Limitation throughout the term of this permit.
The TN allocations of the co-permittee members can change as the result of purchases, sales, trades,
leases, and other transactions. These changes, in turn, affect the Association's TN allocation.
Changes in membership also affect the Association's allocation due to the addition or subtraction of
the discharger's allocation from the group total.
Whenever changes in the allocations or the membership occur, Appendix A of the permit must be
modified in order to formally incorporate those changes and adjust the enforceable limits in the
permit.
The TN allocations and limits are expressed as calendar year values; therefore, any adjustments can
become effective only at the beginning of the calendar year (January 1) following the transaction or
membership change. The Association will notify the Division each year of proposed changes in
Appendix A (see Reporting Requirements, below).
Co-Permittee Members
Table 1 lists the Association's co-permittee members and facilities.
Appendix A of the permit shows in tabular form the original allocations assigned to each member
facility and any transfers or adjustments. It includes discharge and delivered (estuary) values and
lists reserve allocations separately from active allocations.
The Association also holds the TN allocation originally assigned to Burlington Industries (formerly
NC0001376), which the industry deeded to the Association.
Monitoring Requirements
All members of the Association are required under their individual NPDES permits to monitor TN
on a regular basis and report the results in their Discharge Monitoring Reports (DMRs). The group
permit does not duplicate these monitoring requirements or require additional TN monitoring.
Instream monitoring is not required under this permit. However, it is required of the co-permittee
members through their individual NPDES permits and, for most, is conducted by the Lower Neuse
Basin Association, a coalition of dischargers that, by agreement with the Division, conducts
instream monitoring for its members.
Reporting Requirements
Each member will continue to report its TN monitoring results on its individual DMRs. The
Association is not required to duplicate these detailed reports.

Neuse River Compliance Association FACT SHEET
NPDES No. NCC000001 FINAL NPDES PERMIT
Under the current permit, the Association submits year-end, mid -year, and 5-year reports on its
activities to the Division. The year-end report includes an accounting of the Association's and its
members' TN discharges for the previous calendar year for compliance purposes. It also includes a
list of transactions during that period affecting TN allocations, an assessment of progress made, and
planned activities for the coming year. The mid -year report (due August 31 of each year) includes
an updated accounting of TN discharges for informational purposes. It also identifies any changes
in TN allocations or in membership for the following year and serves as a request to modify
Appendix A to incorporate those changes. The 5-year report is intended to ensure that the Division
and the Association agree on the group and individual allocations at the end of the permit term.
Table X. NRCA Members and Discharge Points
#
Owner
Facility
Permit
Receiving Stream
Outfall
Latitude
Longitude
1
Town of Apex
Apex WRF
NC0064050
UT Middle Cr.1
001
35° 42' 30"
-78° 50' 03"
2
Aqua NC
Neuse Colony WWTP
NC0064564
Neuse River
001
35° 38' 44"
-78° 24' 20"
3
Town of Benson
Benson WWTP
NC0020389
Hannah Cr.
001
35° 23' 21"
-78° 30' 29"
4
Town of Cary
4.1
4.2
North Cary WRF
South Cary WRF
NC0048879
NC0065102
Crabtree Cr.
Middle Cr.
001
001
35° 50' 16"
35° 38' 48"
-78° 46' 50"
-78° 45' 28"
5
Town of Clayton
Little Creek WWTP
NC0025453
Neuse River
001
35° 39' 59"
-78° 25' 26"
6
Contentnea MSD
CMSD WWTP
NC0032077
Contentnea Cr.
001
35° 21' 20"
-77° 24' 58"
7
CWS Systems, Inc.
Fairfield Harbour WWTP
NC0033111
Neuse River
001
35° 03' 27'
-77° 57' 33"
8
DuPont - Kinston
E. I. DuPont -Kinston WWTP
NC0003760
Neuse River
001
35° 19' 30"
-77° 28' 13.7"
9
Town of Farmville
Farmville WWTP
NC0029572
Contentnea Cr.
001
35°35' 11.3"
-77° 32' 31.1"
10
City of Goldsboro
Goldsboro WWTP
NC0023949
Neuse River
001
002
35° 20' 44"
35° 20' 14"
-77° 59' 59"
-77° 59' 53"
11
City of Havelock
Havelock WWTP
NC0021253
Neuse River
001
34° 57' 11"
76° 52' 37"
12
Johnston County
Central Johnston Co. WWTP
NC0030716
Neuse River
001
35° 30' 04"
-78°22' 32"
13
Town of Kenly
Kenly Regional WWTP
NC0064891
Little River
001
35° 34' 58"
-78° 09' 32.6"
14
City of Kinston
Kinston Regional WRF
NC0024236
Neuse River
001
35° 17' 15"
-77° 30' 41"
15
Town of LaGrange
La Grange WWTP
NC0021644
UT Moseley Cr.1
001
35° 18'35.4"
-77° 46' 31.2"
16
MCAS - Cherry Point
Cherry Point WWTP
NC0003816
Neuse River
001
34° 57' 11"
-77° 53' 13"
17
City of New Bern
New Bern WWTP
NC0025348
Neuse River
001
35° 08' 20"
-77° 03' 37"
18
Duke Energy
Lee Steam Electric Plant
NC0003417
Neuse River
001
35° 22' 45.3"
-78° 4' 6.46"
19
South Granville WASA
SGWASA WWTP
NC0026824
Knapp of Reed Cr.
001
36°07' 39"
-78° 47' 57"
20
City of Raleigh
20.1
20.2
20.3
Neuse River WWTP
Smith Creek WWTP
Little Creek WWTP
NC0029033
NC0030759
NC0079316
Neuse River
Smith Cr.
Little Cr.
001
001
001
35° 43' 04"
35° 54' 23"
35° 48' 57"
-78° 29' 49"
-78° 32' 15"
-78° 16' 20"
21
City of Wilson
Wilson WWTP
NC0023906
Contentnea Cr.
001
34° 40' 37"
-77° 54' 51"
22
Craven County
Craven WTP
NC0084460
Neuse River
001
35° 58'35"
76° 56' 1"
1 UT = Unnamed Tributary
Compliance
The Association is in compliance with its TN limit when the group does not exceed the Estuary TN
Limitation in Appendix A.
Members are deemed to be in compliance with their individual TN limits in this permit when the
Association as a whole complies with its Estuary TN Limitation. Individual members of the
Association will be subject to individual TN limits only in those years in which the Association

Neuse River Compliance Association FACT SHEET
NPDES No. NCC000001 FINAL NPDES PERMIT
exceeds its limit. In that case, each co-permittee member is subject to its individual TN limit from
Appendix A.
The Association is required by rule to make offset payments to the Wetlands Restoration Fund for
any calendar year in which it exceeds its TN limit. In addition, the Division may take appropriate
enforcement action against the Association or its co-permittee members or both in the event that
they exceed applicable TN limits in the permit.
The Association has not exceeded its TN limit since its formation. The group's combined nitrogen
reduction has been exemplary, reaching approximately 70% reduction from 1995 baseline levels as
compared to the mandated 30% reduction for point source discharges in the basin.
SUMMARY OF CHANGES
The Association's group TN limit was 1,190,831 lb/yr at the previous permit renewal (CY2014). The
permit has been modified twice since that time.
• Craven County Water Treatment Plant was added as a co-permittee member beginning
with CY2015; the County is leasing allocation from the Association for its new discharge.
• A portion of SGWASA's TN allocation was placed in reserve status beginning with CY2016.
Effective in 2016, the facility became subject to a more stringent TN limit under the Falls
Lake Nutrient Management Strategy. Its active allocation was reduced by 3,618 lb/yr
(estuary load) to match the newer limit. The Association's group cap was reduced by the
same amount, to 1,187,213 lb/yr. Appendix A still includes the reserve allocation, but the
reserve does not count toward the group's TN limit.
For this renewal, the NRCA's group TN limit remains at 1,187,213 lb/yr.
RESPONSE TO COMMENTS
No comments were received during the 30-day comment period. The permit was issued without
modification, as proposed.
- end of fact sheet -

APPENDIX B

12/13/21, 10:09 AM DWR :: Local Water Supply Planning
Benson
2018
The Division of Water Resources (DWR) provides the data contained within this Local Water Supply Plan (LWSP) as a courtesy and service to our
customers. DWR staff does not field verify data. Neither DWR, nor any other party involved in the preparation of this LWSP attests that the data is
completely free of errors and omissions. Furthermore, data users are cautioned that LWSPs labeled PROVISIONAL have yet to be reviewed by DWR
staff. Subsequent review may result in significant revision. Questions regarding the accuracy or limitations of usage of this data should be directed to the
water system and/or DWR.
1. System Information
Contact Information
Water System Name:
Mailing Address:
Contact Person:
Phone:
Secondary Contact:
Mailing Address:
Benson
P.O. Box 69
Benson, NC 27504
Tim Robbins
919-894-3553
Dennis Ray Adams
PO Box 69
Benson, NC 27504
PWSID: 03-51-025
Ownership: Municipality
Title:
Cell/Mobile:
Phone:
Cell/Mobile:
Public Works Director
919-894-3553
Complete
Distribution System
Line Type
Asbestos Cement
Cast Iron
Ductile Iron
Galvanized Iron
Polyvinyl Chloride
Size Range (Inches)
4-16
6-12
6-16
1-2
2-8
Estimated % of lines
9.00
15.00 %
35.00 %
15.00 %
26.00 %
What are the estimated total miles of distribution system lines? 37 Miles
How many feet of distribution lines were replaced during 2018? 60 Feet
How many feet of new water mains were added during 2018? 0 Feet
How many meters were replaced in 2018? 7
How old are the oldest meters in this system? 3 Year(s)
How many meters for outdoor water use, such as irrigation, are not billed for sewer services? 27
What is this system's finished water storage capacity? 0.3000 Million Gallons
Has water pressure been inadequate in any part of the system since last update? Line breaks that were repaired quickly should not be included. No
Does this system have a program to work or flush hydrants" Yes, Weekly
Does this system have a valve exercise program? Yes, Annually
Does this system have a cross -connection program? Yes
Does this system have a program to replace meters? Yes
Does this system have a plumbing retrofit program? Yes
Does this system have an active water conservation public education program? Yes
Does this system have a leak detection program? Yes
https://www. ncwater. org/W U DC/app/LW S P/report. php?pwsid=03-51-025&year=2018
1/4

12/13/21, 10:09 AM
DWR :: Local Water Supply Planning
Our town has implemented automatic metering infrastructure (AMI) to our water system. We are currently utilizing the leak detection alert capability
that the AMI system contains to find and report leaks to our customers. The town is looking to further utilize the capability of the AMI system to detect
leaks within the distribution system main lines. Main line leak detection is currently reported by the public works staff who are constantly monitoring
the distribution system while traveling to work assignments. Additionally, the town requests assistance on ocassion from the NCRWA to help locate
leaks within our distribution system.
Water Conservation
What type of rate structure is used? Flat/Fixed
How much reclaimed water does this system use? 0.0000 MGD For how many connections? 0
Does this system have an interconnection with another system capable of providing water in an emergency? Yes
2. Water Use Information
Sub-Basin(s)
Cape Fear River (02-3)
Neuse River (10-1)
% of Service Population
97 %
3%
What was the year-round population served in 2018? 3,965
Has this system acquired another system since last report? No
County(s)
Johnston
% of Service Population
100 %
Type of Use
Residential
Commercial
Industrial
Institutional
Metered
Connections
1,554
286
7
16
Metered
Average Use (MGD)
0.1670
0.0970
0.1390
0.2380
Non -Metered
Connections
0
0
0
0
Non -Metered
Estimated Use (MGD)
0.0000
0.0000
0.0000
0.0000
How much water was used for system processes (backwash, line cleaning, flushing, etc.)? 0.0480 MGD
® The industrial and institutional connections and usage data was incorrectly documented prior to mid 2018. Industrial data was recorded as institutional
and institutional data was recorded as industrial. The issue was corrected upon discovery and the data entered in this local water supply plan reflects
the corrected data.
Purchaser
Johnston County
Average
PWSID Daily Sold
(MGD)
03-51-070 0.0019
Days
Used
Contract
MGD Expiration
365 0.0100 2026
Required to
comply with water
Recurring use restrictions?
Yes
Yes
Pipe Size(s) Use
(Inches) Type
12 Regular
3. Water Supply Sources
Average Daily Max Day Average Daily
Use (MGD) Use (MGD) Use (MGD)
Jan 0.7650 0.9350 May 0.8790
Feb 0.8000 0.9950 Jun 0.8940
Mar 0.8350 0.9770 Jul 0.9090
Apr 0.8110 0.9350 Aug 0.9000
Max Day
Use (MGD)
1.0030
1.0250
1.0740
1.0410
Average Daily
Use (MGD)
Sep 0.7550
Oct 0.8910
Nov 0.8120
Dec 0.8140
Max Day
Use (MGD)
0.8930
1.0390
0.9140
1.0110
Water Purchases From Other Systems
Seller
PWSID
Average
Daily Purchased
(MGD)
Days
Used
Contract
MGD Expiration Recurring
Required to
comply with water
use restrictions?
Pipe Size(s) Use
(Inches) Type
https://www.ncwater.org/WUDC/app/LWSP/report.php?pwsid=03-51-025&year=2018
2/4

12/13/21, 10:09 AM DWR :: Local Water Supply Planning
Dunn 03-43-010 0.7500 365 1.2000 2027 Yes
Johnston County 03-51-070 0.0890 365 0.0900 2026 Yes
Yes
Yes
16
12
Regular
Regular
4. Wastewater Information
Jan
Feb
Mar
Apr
Average Daily
Discharge (MGD)
0.7450
0.9280
0.9750
0.9490
May
Jun
Jul
Aug
Average Daily
Discharge (MGD)
1.0260
0.9550
0.8100
1.4250
Sep
Oct
Nov
Dec
Average Daily
Discharge (MGD)
1.6990
1.1670
1.5340
1.7040
Million Gallons Per Day (MGD)
2
1
0
k
Benson's 2018 Monthly Discharges
Teo 9 o
Avg Daily
How many sewer connections does this system have? 1,704
How many water service connections with septic systems does this system have? 130
Are there plans to build or expand wastewater treatment facilities in the next 10 years? No
Wastewater Permits
Permit
Number
NC0020389
Permitted Capacity Design Capacity
(MGD)
(MGD)
Average Annual
Daily Discharge
(MGD)
Maximum Day Discharge
(MGD)
Receiving Stream Receiving Basin
1.9000 2.1000 1.1600 Hannah Creek Neuse River (10-1)
Water System
Johnston County
PWSID
03-51-070
Type
Receiving
Average Daily Amount
MGD Days Used
0.1340 365
Contract
Maximum (MGD)
0.1920
5. Planning
Projections
Year -Round Population
Seasonal Population
2018
3,965
0
2020
4,190
0
2030
4,665
0
2040
5,190
0
2050
5,200
0
2060
5,210
0
Residential
Commercial
Industrial
Institutional
System Process
0.1670
0.0970
0.1390
0.2380
0.0480
0.1690
0.0990
0.1400
0.2385
0.0480
0.1700
0.1080
0.1450
0.2400
0.0450
0.1710
0.1100
0.1500
0.2410
0.0400
0.1790
0.1210
0.1550
0.2420
0.0350
0.1820
0.1220
0.1600
0.2430
0.0300
Unaccounted-for 0.1481 0.1493
https://www.ncwater.org/WUDC/app/LWSP/report.php?pwsid=03-51-025&year=2018
0.1522 0.1530
0.1573 0.1584
3/4

12/13/21, 10:09 AM
DWR :: Local Water Supply Planning
Surface Water Supply
Ground Water Supply
Purchases
Future Supplies
Total Available Supply (MGD)
Service Area Demand
Sales
Future Sales
Total Demand (MGD)
Demand as Percent of Supply
2018 2020 2030 2040 2050 2060
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
1.2900 1.2900 1.2900 1.2900 1.2900 1.2900
0.0000 0.0000 0.0000 0.0000 0.0000
1.2900 1.2900 1.2900 1.2900 1.2900 1.2900
0.8371 0.8438 0.8602 0.8650 0.8893 0.8954
0.0019 0.0100 0.0100 0.0100 0.0100 0.0100
0.0000 0.0000 0.0000 0.0000 0.0000
0.8390 0.8538 0.8702 0.8750 0.8993 0.9054
65% 66% 67% 68% 70% 70%
The purpose of the above chart is to show a general indication of how the long-term per capita water demand changes over time. The per capita water demand
may actually be different than indicated due to seasonal populations and the accuracy of data submitted. Water systems that have calculated long-term per
capita water demand based on a methodology that produces different results may submit their information in the notes field.
Your long-term water demand is 42 gallons per capita per day. What demand management practices do you plan to implement to reduce the per capita water
demand (i.e. conduct regular water audits, implement a plumbing retrofit program, employ practices such as rainwater harvesting or reclaimed water)? If these
practices are covered elsewhere in your plan, indicate where the practices are discussed here.
Are there other demand management practices you will implement to reduce your future supply needs?
What supplies other than the ones listed in future supplies are being considered to meet your future supply needs?
How does the water system intend to implement the demand management and supply planning components above?
Additional Information
Has this system participated in regional water supply or water use planning? No
What major water supply reports or studies were used for planning?
Please describe any other needs or issues regarding your water supply sources, any water system deficiencies or needed improvements (storage, treatment,
etc.) or your ability to meet present and future water needs. Include both quantity and quality considerations, as well as financial, technical, managerial,
permitting, and compliance issues: The Town of Benson is participating in a year -long water loss program through Cavanaugh Solutions, the NC Water
Resources Research Institute, and the NC Division of Water Infrastructure. The program will include technical assistance to the town in completing a validated
water audit and water loss profile, help to identify the gap between current water loss and optimum water loss levels and present recommendations to the town
for the next steps in water loss control. Completion of the program will assist the town in meeting the present and future water needs of its customers.
The Division of Water Resources (DWR) provides the data contained within this Local Water Supply Plan (LWSP) as a courtesy and service to our
customers. DWR staff does not field verify data. Neither DWR, nor any other party involved in the preparation of this LWSP attests that the data is
completely free of errors and omissions. Furthermore, data users are cautioned that LWSPs labeled PROVISIONAL have yet to be reviewed by DWR
staff. Subsequent review may result in significant revision. Questions regarding the accuracy or limitations of usage of this data should be directed to the
water system and/or DWR.
https://www.ncwater.org/WUDC/app/LWSP/report.php?pwsid=03-51-025&year=2018 4/4

12/13/21, 10:10 AM DWR :: Local Water Supply Planning
Benson
2019
The Division of Water Resources (DWR) provides the data contained within this Local Water Supply Plan (LWSP) as a courtesy and service to our
customers. DWR staff does not field verify data. Neither DWR, nor any other party involved in the preparation of this LWSP attests that the data is
completely free of errors and omissions. Furthermore, data users are cautioned that LWSPs labeled PROVISIONAL have yet to be reviewed by DWR
staff. Subsequent review may result in significant revision. Questions regarding the accuracy or limitations of usage of this data should be directed to the
water system and/or DWR.
1. System Information
Contact Information
Water System Name:
Mailing Address:
Contact Person:
Phone:
Secondary Contact:
Mailing Address:
Benson
P.O. Box 69
Benson, NC 27504
Tim Robbins
919-894-3553
Dennis Ray Adams
PO Box 69
Benson, NC 27504
PWSID: 03-51-025
Ownership: Municipality
Title:
Cell/Mobile:
Phone:
Cell/Mobile:
Public Works Director
919-894-3553
Complete
Distribution System
Line Type
Asbestos Cement
Cast Iron
Ductile Iron
Galvanized Iron
Polyvinyl Chloride
Size Range (Inches)
6-16
6-10
6-16
2
2-12
Estimated % of lines
9.90
19.30 %
19.50 %
5.20 %
46.10 %
What are the estimated total miles of distribution system lines? 36 Miles
How many feet of distribution lines were replaced during 2019? 1,130 Feet
How many feet of new water mains were added during 2019? 1,290 Feet
How many meters were replaced in 2019? 8
How old are the oldest meters in this system? 4 Year(s)
How many meters for outdoor water use, such as irrigation, are not billed for sewer services? 27
What is this system's finished water storage capacity? 0.3000 Million Gallons
Has water pressure been inadequate in any part of the system since last update? Line breaks that were repaired quickly should not be included. No
Programs
Does this system have a program to work or flush hydrants" Yes, Weekly
Does this system have a valve exercise program? Yes, Annually
Does this system have a cross -connection program? Yes
Does this system have a program to replace meters? Yes
Does this system have a plumbing retrofit program? Yes
Does this system have an active water conservation public education program? Yes
Does this system have a leak detection program? Yes
https://www. ncwater. org/W U DC/app/LW S P/report. php?pwsid=03-51-025&year=2019
1/4

12/13/21, 10:10 AM
DWR :: Local Water Supply Planning
® Benson utilizes the capabilities of ifs automatic metering infrastructure (AMI), which monitors customer usage and alerts town staff of potential leaks.
Additionally, public works employees are constantly monitoring distribution main lines for leaks. Benson occasionally calls upon the NC Rural Water
Association for assistance in leak detection.
Water Conservation
What type of rate structure is used? Flat/Fixed
How much reclaimed water does this system use? 0.0000 MGD For how many connections? 0
Does this system have an interconnection with another system capable of providing water in an emergency? Yes
2. Water Use Information
Service Area
Sub-Basin(s)
Cape Fear River (02-3)
Neuse River (10-1)
% of Service Population
97 %
3%
What was the year-round population served in 2019? 4,000
Has this system acquired another system since last report? No
County(s)
Johnston
% of Service Population
100 %
Water Use by Type
Type of Use
Residential
Commercial
Industrial
Institutional
Metered
Connections
1,568
295
3
18
Metered
Average Use (MGD)
0.1860
0.1010
0.3700
0.0120
Non -Metered
Connections
Non -Metered
Estimated Use (MGD)
0
0
0.0000
0.0000
0
0
0.0000
0.0000
How much water was used for system processes (backwash, line cleaning, flushing, etc.)? 0.0680 MGD
® The metered average use for industrial and institutional use types are correct, although the numbers reflect a large percentage of increase for
industrial use and a large decrease in institutional use. Our billing department had previously categorized some of the industrial customers as
institutional and some institutional customers as industrial. This issue has been corrected.
Water Sales
Purchaser
Johnston County
PWSID
Average
Daily Sold
(MGD)
Days
Used
Contract
MGD Expiration Recurring
03-51-070 0.0020 365 0.0100 2026 Yes
Required to
comply with water
use restrictions?
Yes
Pipe Size(s)
(Inches)
Use
Type
12 Regular
3. Water Supply Sources
Monthly Withdrawals & Purchases
Jan
Feb
Mar
Apr
Average Daily
Use (MGD)
Max Day
Use (MGD)
0.7730
0.8970
0.7330 0.8630
0.7330 0.9820
0.7370
0.9860
May
Jun
Jul
Aug
Average Daily
Use (MGD)
Max Day
Use (MGD)
0.8240
1.0180
0.8210 0.9560
0.7680 0.9790
0.8390
0.9830
Sep
Oct
Nov
Dec
Average Daily
Use (MGD)
0.8940
0.8990
0.8400
0.8820
Max Day
Use (MGD)
1.0460
1.0210
0.9980
1.0520
Water Purchases From Other Systems
Seller
PWSID
Average
Daily Purchased
(MGD)
Days
Used
Contract
MGD Expiration Recurring
Required to
comply with water
use restrictions?
Pipe Size(s)
(Inches)
Use
Type
Dunn
03-43-010 0.7240 365 1.2000 2027 Yes
https://www.ncwater.org/WUDC/app/LWSP/report.php?pwsid=03-51-025&year=2019
Yes
16 Regular
2/4

12/13/21, 10:10 AM DWR :: Local Water Supply Planning
Johnston County 03-51-070 0.0890 365 0.0900 2026 Yes
Yes
12 Regular
4. Wastewater Information
Monthly Discharges
Jan
Feb
Mar
Apr
Average Daily
Discharge (MGD)
1.4000
1.2360
1.4390
1.3530
May
Jun
Jul
Aug
Average Daily Average Daily
Discharge (MGD) Discharge (MGD)
1.0040
1.0580
0.9390
1.2360
Sep 1.3980
Oct 1.1570
Nov 1.1110
Dec 1.5540
Million Gallons Per Day (MGD)
2
1
0
Benson's 2019 Monthly Discharges
°411 0. ' 4 ' o 4 P4 4?
Avg Daily
How many sewer connections does this system have? 1,715
How many water service connections with septic systems does this system have? 129
Are there plans to build or expand wastewater treatment facilities in the next 10 years? No
Wastewater Permits
Permit
Number
NC0020389
Permitted Capacity Design Capacity
(MGD)
(MGD)
Average Annual
Daily Discharge
(MGD)
Maximum Day Discharge
(MGD)
Receiving Stream Receiving Basin
1.9000 2.1000 1.2380 Hannah Creek Neuse River (10-1)
Wastewater Interconnections
Water System
Johnston County
PWSIC
03-51-070
Receiving
0.1050
Average Daily Amount
MGD Days Used
365
Contract
Maximum (MGD)
0.1920
5. Planning
Projections
2019 2020 2030 2040 2050 2060
Year -Round Population
Seasonal Population
4,000
0
4,050 4,550 5,150 5,650 6,150
0 0 0 0
0
Residential 0.1860 0.2050
0.1030
0.3700
0.0140
0.0650
Unaccounted-for 0.0740 0.0697
Commercial 0.1010
Industrial 0.3700
Institutional
System Process
0.0120
0.0680
0.2100 0.2200 0.2300 0.2350
0.1210 0.1220
0.3700 0.3700
0.0160 0.0160
0.0500 0.0450
0.0711 0.0715 0.0735 0.0740
0.1050 0.1070
0.3700 0.3700
0.0160 0.0160
0.0600 0.0550
https://www.ncwater.org/WUDC/app/LWSP/report.php?pwsid=03-51-025&year=2019 3/4

12/13/21, 10:10 AM
DWR :: Local Water Supply Planning
Demand v/s Percent of Supply
Surface Water Supply
Ground Water Supply
Purchases
Future Supplies
Total Available Supply (MGD)
Service Area Demand
Sales
Future Sales
Total Demand (MGD)
Demand as Percent of Supply
r.
2019 2020 2030 2040 2050 2060
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
1.2900 1.2900 1.2900 1.2900 1.2900 1.2900
0.0000 0.0000 0.0000 0.0000 0.0000
1.2900 1.2900 1.2900 1.2900 1.2900 1.2900
0.8110 0.8267 0.8321 0.8395 0.8605 0.8620
0.0020 0.0100 0.0100 0.0100 0.0100 0.0100
0.0000 0.0000 0.0000 0.0000 0.0000
0.8130 0.8367 0.8421 0.8495 0.8705 0.8720
63% 65% 65% 66% 67% 68%
The purpose of the above chart is to show a general indication of how the long-term per capita water demand changes over time. The per capita water demand
may actually be different than indicated due to seasonal populations and the accuracy of data submitted. Water systems that have calculated long-term per
capita water demand based on a methodology that produces different results may submit their information in the notes field.
Your long-term water demand is 47 gallons per capita per day. What demand management practices do you plan to implement to reduce the per capita water
demand (i.e. conduct regular water audits, implement a plumbing retrofit program, employ practices such as rainwater harvesting or reclaimed water)? If these
practices are covered elsewhere in your plan, indicate where the practices are discussed here.
Are there other demand management practices you will implement to reduce your future supply needs? We currently utilize automatic metering infrastructure to
monitor for service line leaks. We hope to expand this benefit to include main line monitoring in the near future. This would help to greatly reduce our
unaccounted for water percentage.
What supplies other than the ones listed in future supplies are being considered to meet your future supply needs?
How does the water system intend to implement the demand management and supply planning components above?
Additional Information
Has this system participated in regional water supply or water use planning? No
What major water supply reports or studies were used for planning?
Please describe any other needs or issues regarding your water supply sources, any water system deficiencies or needed improvements (storage, treatment,
etc.) or your ability to meet present and future water needs. Include both quantity and quality considerations, as well as financial, technical, managerial,
permitting, and compliance issues: Our town is fortunate to have implemented automatic metering infrastructure into our water distribution system. The system
provides numerous functions that help us to better manage costs and continually improve our efficiency and accountability. The system has additional capabilities
not yet utilized that will enhance our management of present and future water needs.
The Division of Water Resources (DWR) provides the data contained within this Local Water Supply Plan (LWSP) as a courtesy and service to our
customers. DWR staff does not field verify data. Neither DWR, nor any other party involved in the preparation of this LWSP attests that the data is
completely free of errors and omissions. Furthermore, data users are cautioned that LWSPs labeled PROVISIONAL have yet to be reviewed by DWR
staff. Subsequent review may result in significant revision. Questions regarding the accuracy or limitations of usage of this data should be directed to the
water system and/or DWR.
https://www.ncwater.org/WUDC/app/LWSP/report.php?pwsid=03-51-025&year=2019 4/4

12/13/21, 10:10 AM DWR :: Local Water Supply Planning
Benson
2020
The Division of Water Resources (DWR) provides the data contained within this Local Water Supply Plan (LWSP) as a courtesy and service to our
customers. DWR staff does not field verify data. Neither DWR, nor any other party involved in the preparation of this LWSP attests that the data is
completely free of errors and omissions. Furthermore, data users are cautioned that LWSPs labeled PROVISIONAL have yet to be reviewed by DWR
staff. Subsequent review may result in significant revision. Questions regarding the accuracy or limitations of usage of this data should be directed to the
water system and/or DWR.
1. System Information
Contact Information
Water System Name:
Mailing Address:
Contact Person:
Phone:
Secondary Contact:
Mailing Address:
Benson
P.O. Box 69
Benson, NC 27504
Tim Robbins
919-894-3553
Dennis Ray Adams
PO Box 69
Benson, NC 27504
PWSID: 03-51-025
Ownership: Municipality
Title:
Cell/Mobile:
Phone:
Cell/Mobile:
Public Works Director
919-894-3553
Complete
Distribution System
Line Type
Asbestos Cement
Cast Iron
Ductile Iron
Galvanized Iron
Polyvinyl Chloride
Size Range (Inches)
6-16
6-10
6-16
2
2-12
Estimated % of lines
9.90 %
19.30 %
19.50 %
5.20 %
46.10 %
What are the estimated total miles of distribution system lines? 36 Miles
How many feet of distribution lines were replaced during 2020? 750 Feet
How many feet of new water mains were added during 2020? 1,200 Feet
How many meters were replaced in 2020? 6
How old are the oldest meters in this system? 5 Year(s)
How many meters for outdoor water use, such as irrigation, are not billed for sewer services? 27
What is this system's finished water storage capacity? 0.3000 Million Gallons
Has water pressure been inadequate in any part of the system since last update? Line breaks that were repaired quickly should not be included. No
Programs
Does this system have a program to work or flush hydrants? Yes, Weekly
Does this system have a valve exercise program? Yes, Annually
Does this system have a cross -connection program? Yes
Does this system have a program to replace meters? Yes
Does this system have a plumbing retrofit program? Yes
Does this system have an active water conservation public education program? Yes
Does this system have a leak detection program? Yes
https://www.ncwater.org/WUDC/app/LWSP/report.php?pwsid=03-51-025&year=2020
1/4

12/13/21, 10:10 AM
DWR :: Local Water Supply Planning
® The leak detection program consists of the town's AMI system, which monitors customer water usage in real time to detect possible leaks and alerts
town staff. The town also owns leak detection equipment which is utilized regularly to locate leaks, and the town also calls upon NCRWA on occasion
to conduct leak detection surveys. Additionally, public works staff are instructed to observe and report water leaks as they travel during their shift.
Water Conservation
What type of rate structure is used? Flat/Fixed
How much reclaimed water does this system use? 0.0000 MGD For how many connections? 0
Does this system have an interconnection with another system capable of providing water in an emergency? Yes
2. Water Use Information
Service Area
Sub-Basin(s)
% of Service Population
Cape Fear River (02-3)
Neuse River (10-1)
97 %
3%
What was the year-round population served in 2020? 4,080
Has this system acquired another system since last report? No
County(s)
Johnston
% of Service Population
100 %
Water Use by Type
Type of Use
Residential
Commercial
Industrial
Institutional
Metered
Connections
Metered
Average Use (MGD)
Non -Metered
Connections
1,600
0.1950
0
293
3
0.1030
0.4260
0
0
15
0.0080
0
Non -Metered
Estimated Use (MGD)
0.0000
0.0000
0.0000
0.0000
How much water was used for system processes (backwash, line cleaning, flushing, etc.)? 0.0612 MGD
Water Sales
Purchaser
Johnston County
Average
PWSID Daily Sold
(MGD)
Days
Used
Contract
MGD Expiration
03-51-070 0.0020 366 0.0100 2026
Required to
comply with water
Recurring use restrictions?
Yes
Yes
Pipe Size(s) Use
(Inches) Type
12 Regular
3. Water Supply Sources
Monthly Withdrawals & Purchases
Average Daily
Use (MGD)
Jan 0.8700
Feb 0.7590
Mar 0.7640
Apr 0.8130
Max Day
Use (MGD)
0.9670
0.8310
0.9840
0.9850
Average Daily
Use (MGD)
May 0.8930
Jun 0.8900
Jul 0.9660
Aug 0.8650
Max Day
Use (MGD)
Average Daily
Use (MGD)
1.0450 Sep 0.9070
Oct 0.9610
Nov 0.9390
1.1330 Dec 0.8260
0.9920
1.1150
Max Day
Use (MGD)
1.0120
1.1110
1.1020
1.0190
Water Purchases From Other Systems
Seller
PWSID
Average
Daily Purchased
(MGD)
Days
Used
Contract
MGD Expiration Recurring
Dunn
03-43-010 0.7920 366 1.2000 2027 Yes
Johnston County 03-51-070 0.0930 366 0.0900 2026 Yes
Required to
comply with water
use restrictions?
Pipe Size(s)
(Inches)
Yes
Yes
16
12
Use
Type
Regular
Regular
4. Wastewater Information
https://www.ncwater.org/WUDC/app/LWSP/report.php?pwsid=03-51-025&year=2020
2/4

12/13/21, 10:10 AM
DWR :: Local Water Supply Planning
Monthly Discharges
Jan
Feb
Mar
Apr
Average Daily
Discharge (MGD)
1.6500
1.9400
1.3280
1.1050
May
Jun
Jul
Aug
Average Daily
Discharge (MGD)
1.4130
1.6550
1.2020
1.8880
Sep
Oct
Nov
Dec
Average Daily
Discharge (MGD)
1.8090
1.5060
1.7250
1.5790
Million Gallons Per Day (MGD)
2
Benson's 2020 Monthly Discharges
k 4 06+94
-
Avg Daily
How many sewer connections does this system have? 1,786
How many water service connections with septic systems does this system have? 129
Are there plans to build or expand wastewater treatment facilities in the next 10 years? Yes
® We are currently pursuing engineering options to expand the wastewater treatment facility due to growth and development in our area. More details
should be available by next years LWSP update.
Wastewater Permits
Permit
Number
NC0020389
Permitted Capacity Design Capacity
(MGD)
(MGD)
Average Annual
Daily Discharge
(MGD)
Maximum Day Discharge
(MGD)
Receiving Stream Receiving Basin
1.9000 2.1000 1.5670 Hannah Creek Neuse River (10-1)
Wastewater Interconnections
Water System
Johnston County
PWSID
03-51-070
Type
Receiving
Average Daily Amount
MGD Days Used
0.1020 366
Contract
Maximum (MGD)
0.1920
5. Planning
Projections
2020 2030 2040 2050 2060 2070
Year -Round Population
Seasonal Population
4,080
0
4,130 4,180 4,230 4,280 5,300
0 0 0
0 0
Residential
Commercial
0.1950
0.1030
Industrial
Institutional
0.4260
0.0080
System Process
Unaccounted-for
0.0612
0.0898
0.2040
0.1050
0.5200
0.0085
0.0600
0.0740
0.2130 0.2220
0.1070 0.1090
0.5300 0.5300
0.0087 0.0089
0.0600 0.0600
0.0745 0.0747
0.2310 0.2400
0.1110 0.1130
0.5300 0.5300
0.0091 0.0093
0.0600 0.0600
0.0749 0.0751
https://www.ncwater.org/WUDC/app/LWSP/report.php?pwsid=03-51-025&year=2020
3/4

12/13/21, 10:10 AM
DWR :: Local Water Supply Planning
Demand v/s Percent of Supply
Surface Water Supply
Ground Water Supply
Purchases
Future Supplies
Total Available Supply (MGD)
Service Area Demand
Sales
Future Sales
Total Demand (MGD)
Demand as Percent of Supply
r.
2020 2030 2040 2050 2060 2070
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
1.2900 1.2930 1.2930 1.2930 1.2930 1.2930
0.0000 0.0000 0.0000 0.0000 0.0000
1.2900 1.2930 1.2930 1.2930 1.2930 1.2930
0.8830 0.9715 0.9932 1.0046 1.0160 1.0274
0.0020 0.0100 0.0100 0.0100 0.0100 0.0100
0.0000 0.0000 0.0000 0.0000 0.0000
0.8850 0.9815 1.0032 1.0146 1.0260 1.0374
69% 76% 78% 78% 79% 80%
The purpose of the above chart is to show a general indication of how the long-term per capita water demand changes over time. The per capita water demand
may actually be different than indicated due to seasonal populations and the accuracy of data submitted. Water systems that have calculated long-term per
capita water demand based on a methodology that produces different results may submit their information in the notes field.
Your long-term water demand is 48 gallons per capita per day. What demand management practices do you plan to implement to reduce the per capita water
demand (i.e. conduct regular water audits, implement a plumbing retrofit program, employ practices such as rainwater harvesting or reclaimed water)? If these
practices are covered elsewhere in your plan, indicate where the practices are discussed here.
Are there other demand management practices you will implement to reduce your future supply needs?
What supplies other than the ones listed in future supplies are being considered to meet your future supply needs?
How does the water system intend to implement the demand management and supply planning components above?
Additional Information
Has this system participated in regional water supply or water use planning? Yes, We are currently participating in a merger regionalization study with the City of
Dunn. Study initiated in February 2021
What major water supply reports or studies were used for planning?
Please describe any other needs or issues regarding your water supply sources, any water system deficiencies or needed improvements (storage, treatment,
etc.) or your ability to meet present and future water needs. Include both quantity and quality considerations, as well as financial, technical, managerial,
permitting, and compliance issues:
The Division of Water Resources (DWR) provides the data contained within this Local Water Supply Plan (LWSP) as a courtesy and service to our
customers. DWR staff does not field verify data. Neither DWR, nor any other party involved in the preparation of this LWSP attests that the data is
completely free of errors and omissions. Furthermore, data users are cautioned that LWSPs labeled PROVISIONAL have yet to be reviewed by DWR
staff. Subsequent review may result in significant revision. Questions regarding the accuracy or limitations of usage of this data should be directed to the
water system and/or DWR.
https://www.ncwater.org/WUDC/app/LWSP/report.php?pwsid=03-51-025&year=2020 4/4

Flow Total Flow AVG Flow Min Flow Max BOD AVG BOD Min BOD Max NH3 AVG NH3 Min NH3 Max TSS AVG TSS Min TSS Max TN AVG TN Min TN Max TP AVG TP Min TP Max
Month (MGD) (MGD) (MGD) (MGD) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L)
Detection Values = 0 for results <
Limit <2.0 <0.04 <2.5 Detection Limit
2018
January 23.102998 0.745258 0.445 1.589 4.442857 0 43 2.568571 0.26 3.85 8.704762 0 20 3.97 1.63 6.15 1.024 0.76 1.58
February 25.982012 0.927929 0.67 1.398 4.385 0 18 1.5215 0 2.88 7.0225 0 14.6 2.83 1.59 4.13 0.5025 0.31 0.68
March 30.232006 0.975226 0.646 1.339 5.966667 0 25 1.839286 0 3.84 5.7 0 9 1.9125 0.96 3.35 0.65 0.53 0.78
April 28.473 0.9491 0.675 1.304 4.338095 0 11 1.03381 0 2.97 1.397619 0 6.5 3.23 1.94 5.02 0.8225 0.56 1.42
May 31.799986 1.025806 0.162 1.713 6.545455 0 21 0.767273 0.26 1.64 7.505132 0 17.5 4.685 2.13 6.85 1.165 1.08 1.28
June 28.65 0.954867 0.745 1.406 2.961905 0 8.9 0.217143 0 0.49 1.671429 0 4.6 1.3425 1.07 1.76 1.1 0.72 1.89
July 25.097 0.8095806 0.457 1.376 2.738095 0 10 0.330476 0.18 0.54 1.914286 0 5.9 2.29 1.8 3.08 1.3275 0.79 1.6
August 44.166 1.42471 0.793 2.973 1.352174 0 6.2 0.213043 0 0.56 1.904348 0 7.8 2.814 1.39 3.97 0.866 0.75 0.98
September 50.966 1.66 0.306 6.09 4.7 0 15 2.899444 0 7.9 8.316667 0 28.8 4.3975 2.98 6.06 1.005 0.72 1.18
October 36.174 1.166903 0.581 1.92 1.521739 0 10 0.269565 0 0.46 1.76087 0 3.9 2.6 2.1 3.64 1.055 0.84 1.24
November 46.012 1.536167 0.956 2.339 1.863158 0 6.6 0.683158 0 6.74 2.589474 0 16 3.61 2.1 6.75 1.382 1.14 1.62
December 52.816 1.703742 1.088 2.836 5.433333 0 22 1.240556 0.19 4.74 4.327778 0 10.9 4.155 1.78 7.5 1.2675 0.67 1.62
2019
January 43.414 1.400452 1.063 2.135 1.061905 0 8.2 0.761429 0 12.9 0.595238 0 7.2 2.696 1.62 5.97 1.182 0.94 1.44
February 34.609 1.236036 0.842 1.761 1.045 0 16 0.168 0.04 0.34 0.49 0 4.2 2.6025 2.19 3.23 0.91 0.57 1.4
March 44.6 1.438839 1.176 1.782 1.595238 0 4.3 0.084762 0 0.17 1.314286 0 3.9 3.1 2.46 3.92 2.135 1.71 3.35
April 40.604 1.3821 0.859 2.167 2.266667 0 3.6 0.397619 0.05 2.2 1.009524 0 2.9 3.305 2.85 4.2 1.1275 0.71 1.94
May 31.135 0.605 1.351 1.351 1.559091 0 3.6 0.201818 0.05 0.68 1.486364 0 3 3.574 2.97 4.13 1.756 0.94 2.5
June 31.754 1.058467 0.64 1.625 0.12 0 2.4 0.141 0.04 0.29 0.41 0 2.8 2.8325 2.41 3.3 1.6825 0.51 2.7
July 29.106 0.9482 0.583 1.72 0.431818 0 3.1 0.126091 0 0.45 0.963636 0 2.9 3.496 2.39 5.91 2.562 1.53 4.3
August 37.313 1.203645 0.56 2.261 1.104545 0 4.2 0.103182 0 0.25 1.245455 0 3.1 3.345 2.87 3.74 1.51 1.19 1.94
September 41.926 1.397533 0.881 2.955 1.235 0 4.4 0.455 0 3.21 1.065 0 13.4 2.0925 1.41 3.07 0.6925 0.07 2.5
October 35.861 1.156806 0.63 1.704 1.104348 0 5.3 0.10087 0 0.34 0.121739 0 2.8 2.814 2.17 3.64 1.39 1.09 1.91
November 33.337 1.111233 0.785 1.45 0.577778 0 3.3 0.105 0 0.32 0 0 0 4.76 2.1 6.83 1.6675 1.44 2.02
December 48.178 1.547357 1.067 3.045 2.221053 0 7.2 0.186316 0 1.37 0 0 0 2.32 1.34 3 0.828 0.15 1.68
2020
January 51.139 1.649645 1.244 2.054 2.157143 0 5.8 0.487143 0 2.45 0 0 0 3.0325 1.35 6.3 0.775 0.19 1.3
February 56.266 1.940207 1.356 3.228 3.28 0 6.3 0.379 0 1.18 0.14 0 2.8 2.575 1.52 3.49 0.825 0.47 1.64
March 41.159 1.32771 0.922 1.82 4.286364 0 18 0.258636 0 2.6 0 0 0 2.935 2.26 4.51 1.0475 0.71 1.63
April 33.136 1.104533 0.596 1.632 1.566667 0 6.7 0.050476 0 0.3 1.142857 0 18 2.572 1.87 2.9 1.912 1.75 2.22
May 43.817 1.413452 0.964 2.714 0.65 0 3.2 0.0905 0 0.55 0 0 0 2.282 2.08 2.54 1.246 0.2 2.28
June 49.654 1.655133 0.993 3.412 1.181818 0 4.1 0.057273 0 0.32 0 0 0 2.7875 2.34 3.4 1.775 1.04 2.99
July 37.251 1.201645 0.821 1.876 0.777273 0 4.5 0.048182 0 0.26 0 0 0 2.094 1.6 2.46 1.494 0.94 1.89
August 58.54 1.888387 0.875 2.924 1.2 0 4.3 0.155238 0 1.27 0 0 0 2.2575 1.85 2.86 1.5075 0.61 2.39
September 54.269 1.818793 1.214 3.291 0.580952 0 3.9 0.097619 0 0.3 0 0 0 3.038 1.67 4.65 1.64 1.12 2.56
October 46.68 1.505806 0.826 2.452 0.213636 0 2.4 0.043182 0 0.2 0.127273 0 2.8 2.9325 2.31 3.74 1.71 1.04 2.3
November 51.762 1.7254 1.022 3.625 1.294444 0 4.3 0.075556 0 0.27 0 0 0 3.85 3.19 4.35 1.44 1.3 1.82
December 48.953 1.579129 1 3.176 2.105 0 5.4 0.0595 0 0.13 0 0 0 4.072 2.7 7.23 1.166 0.9 1.59
2021
January 67.998 2.193484 1.3 3.114 2.742105 0 6.6 0.111579 0 0.32 0 0 0 3.6225 2.64 4.74 0.7175 0.15 1.13
February 69.225 2.472321 1.323 4.343 3.015 0 5.8 0.1665 0.04 0.58 0 0 0 3.905 2.93 5.16 0.6275 0.54 0.71
March 52.086 1.720935 1.006 3.021 5.447826 2.8 11 0.476522 0 3.03 0.173913 0 4 3.554 2.56 4.4 0.624 0.35 1.06
April 39.503 1.316767 0.459 1.907 4.361905 2.6 7.6 0.147619 0 1.08 0.12381 0 2.6 2.7025 2.22 3.02 0.5025 0.2 1.16
May 25.108 0.809935 0.3 1.544 2.825 0 4.7 0.076 0 0.33 0.311111 0 2.8 2.985 2.12 4.18 2.1575 1.7 2.69
June 31.376 1.045867 0.741 1.655 1.459091 0 5.4 0.916818 0 17.88 0 0 0 2.938 2.04 4.34 1.926 1.55 2.55 * sampling error annomi
July 46.262 1.522806 0.61 2.677 2.2 0 7.5 0.164762 0.05 0.92 0.311111 0 2.8 2.6825 2.33 3.01 1.48 0.65 2.64
August 34.371 1.108742 0.636 2.08 2.05 0 5.5 0.103182 0 0.31 0 0 0 4.59 3.63 5.13 2.4075 2.16 2.61
September 26.13 0.871 0.476 0.903
October 25.341 0.817 0.39 1.247
November 25.103 0.837 0.012 1.734
December 0

Flow Projections
(Last updated_ May 2015)
3-2.2 Flow Projections
Determining future flow is critical to ensuring that the project is properly sized to accommodate
future flows. Since population projections determine flows, be sure to complete the population
project as discussed in Subchapter 3.2.1 above.
The design flow for a NPDES permitted facility is defined as the maximum monthly flow.
Therefore, the current flow is based on the average of the last four years of Max. Month flows
(see Subchapter 2.2.4 of this part). Utilize Equation B.3. 1 below to calculate future flows. If the
design life of the project is 20 years or greater, calculate the future flow at Year 20 using this
equation. If the design life is Iess than 20 years, then do a year -by -year flow projection and
explain how this project fits in with the future expansions to accommodate the 20-year design
flaw.
if the WYW CP service area expansion can be described as a well-defined residential/oommerciul
area, use North Carolina 2T Standards 15A NCAC 02T .0114 to characterize the future flow.
Design Flow (Max. Month) for Year 20
Cement average Marc Month for W WTP
Industrial or other known non-residernial and non-commercial flow. This future
industrial flow must be documented.
Population for current year
Population at Year 20
Population at Year 20 - Pearnenr
Equation 5.3.1. Flow Projection Calculation
Different methodologies may also be used for flow projections. In the body of the ERIEID,
explain the methodology used and present the results. All supporting information, assumptions
made, and calculations should be provided in an appendix to the ERIEID.
Flow
SDC COUNTY DATA
Benson - Historical Max Month Flows (per LWSP)
Year
2018
2019
2020
2021
Flow per Capita:
P2021
P2041
AP
QBeey Global
Q2041
2.5 peaking factor 9.391 mgd
Q,, (mgd)
1.704
1.554
1.940
2.472
1.918 mgd
100 gpd (new population)
4,122
6,088
1,967
0.400 mgd
0.350 mgd
based on IUP
projected new flow
0.750 mgd
0.450 mgd
0.442 mgd contract flow
3.756 mgd

Population Projections - SDC County Data Method
Year County Pop. Benson Pop. Source/Method
2019 206,016 3,919 https://www.osbm.nc.gov/facts-figures/population-demographics/state-demos
2020 211,626 4,026 Fixed Percent of County Projections (SDC Projections)
2021 216,670 4,122 Fixed Percent of County Projections (SDC Projections)
2022 222,914 4,240 Fixed Percent of County Projections (SDC Projections)
2023 228,440 4,346 Fixed Percent of County Projections (SDC Projections)
2024 233,803 4,448 Fixed Percent of County Projections (SDC Projections)
2025 239,055 4,547 Fixed Percent of County Projections (SDC Projections)
2026 244,237 4,646 Fixed Percent of County Projections (SDC Projections)
2027 249,372 4,744 Fixed Percent of County Projections (SDC Projections)
2028 254,473 4,841 Fixed Percent of County Projections (SDC Projections)
2029 259,553 4,937 Fixed Percent of County Projections (SDC Projections)
2030 264,618 5,034 Fixed Percent of County Projections (SDC Projections)
2031 269,675 5,130 Fixed Percent of County Projections (SDC Projections)
2032 274,723 5,226 Fixed Percent of County Projections (SDC Projections)
2033 279,766 5,322 Fixed Percent of County Projections (SDC Projections)
2034 284,808 5,418 Fixed Percent of County Projections (SDC Projections)
2035 289,846 5,514 Fixed Percent of County Projections (SDC Projections)
2036 294,887 5,610 Fixed Percent of County Projections (SDC Projections)
2037 299,919 5,705 Fixed Percent of County Projections (SDC Projections)
2038 304,955 5,801 Fixed Percent of County Projections (SDC Projections)
2039 309,989 5,897 Fixed Percent of County Projections (SDC Projections)
2040 315,026 5,993 Fixed Percent of County Projections (SDC Projections)
2041 320,061 6,088 Fixed Percent of County Projections (SDC Projections)
7,000
6,000
5,000
4,000
co
3,000
0
o- 2,000
1,000
0
2010 2015 2020 2025 2030 2035 2040
Year

APPENDIX C

Engineering Alternatives
Analysis
Proposed Discharge
Forcemain Alignment
Stone Creek Forcemain
Town of Benson
December 2021
Legend
WWTP
Discharge Point
a Stone Creek (Neuse)
- Interstate
US Route
- NC Route
- Ramp
Municipal Boundary
L__; County Boundary
WWTP
e
1 in = 2,500 feet
0 1,250 2,500 5,000
Feet
Wooten
The Wooten Company makes every effort to produce and publish GIS maps using the most
current and accurate information possible, however the maps are strictly for planning purposes
only. The maps are compiled from recorded deeds, plats, and other public and private records
and data. Users of the maps are hereby notified that the aforementioned public primary
information sources should be consulted for verification of the information on this map. The
Wooten Company assumes NO responsibility for the information contained on the maps unless
the map is signed and sealed by a licensed Professional Land Surveyor. Please contact the
GIS Group at [phone] or tcohan©thewootencompany.com for data source information.

CENTER Of At EN,t ION
Engineering Alternatives
Analysis
Proposed Discharge
Forcemain Alignment
Neuse River Forcemain
Town of Benson
December 2021
Legend
WWTP
WWTP
iN Discharge Point
Neuse River
Interstate
US Route
NC Route
Ramp
1-2, Municipal Boundary
L___; County Boundary
e
1 in = 1 mile
0 0.5 1
2
Miles
Wooten
The Wooten Company makes every effort to produce and publish GIS maps using the most
current and accurate information possible, however the maps are strictly for planning purposes
only. The maps are compiled from recorded deeds, plats, and other public and private records
and data. Users of the maps are hereby notified that the aforementioned public primary
information sources should be consulted for verification of the information on this map. The
Wooten Company assumes NO responsibility for the information contained on the maps unless
the map is signed and sealed by a licensed Professional Land Surveyor. Please contact the
GIS Group at [phone] or [e-mail] for data source information.

� may{.
•
wr
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Engineering Alternatives
Analysis
ProposedDischarge
Forcemain Alignment
Mingo SwampForcemain
►� .�
-�.
�.� ,T
a, s '•��,
I'�I
' l
Town of Benson
y , _ 1-
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December 2021
t! _. ,j
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- :1,.. - r• `x'
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Legend
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i1.' i--,,,,,
a Mingo Swamp (Cape Fear)
L ,
;?
.. _ _ `_� ow_ _ — -- e=
.ice
.-- .-- .+� :. ti�.rq. ;h. ti'1�:5 9K1: ^irk- S_ _-�f'•..
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r E� •
7.:_0'42 a�
r
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... T•
W
° ti -. wTP
US Route
NC Route
y
�'■
_
Ramp
�,. f _
, ,:T 11 ►. ,� .!1
Mingo Swamp .Iiw.
J F
_ 1 Municipal Boundary
;. - ;..'
(eapeG � -� _, •^�'
e
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,
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d 7% h v f 4, .F �:=-fit % '' : !Yr L. ^ ,. ------ \\ ..�ele•�La}�l�M
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•
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_ �' s
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0 1,000 2,000 4,000
_ _ •
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APPENDIX D

Chris White
From: Templeton, Mike <[e-mail]>
Sent: Tuesday, November 23, 2021 3:48 PM
To: Chris White
Cc: Montebello, Michael J
Subject: RE: [External] RE: Town of Benson - EAA and possible discharge to Cape Fear instead of
Neuse
Follow Up Flag: Follow up
Flag Status: Flagged
Hi, Chris —
Here is a brief answer to your questions. I should be available tomorrow afternoon if you have any follow-up questions.
From your voice mail, Can a facility discharge to two different river basins?
I don't know of any reason why a treatment facility could not discharge to two basins, and we should be able to write a
permit that properly regulates both discharges and protects water quality in both receiving streams.
To add a second outfall in a different stream, the Town would have to satisfy all the usual requirements that apply to a
new discharge, just as if it were adding an entirely new facility. The permit could get a bit complicated, depending on the
particular details of the Town's proposal, the characteristics of the new receiving stream, and other factors. For
example, if any of the discharge limits at the new Outfall 002 are more stringent than the limits at Outfall 001, the POTW
could, in effect, have to treat its entire flow to meet the tighter of the limits.
The Town should also consider that we are working to develop a nutrient control strategy for the Middle Cape Fear
basin. We have begun instream monitoring that will provide necessary data for one or more models of the basin. Thus,
the Town could find itself subject to another set of nutrient limits at its new outfall.
From your recent email below, ...if Benson were to discharge all of its treated effluent to the Cape Fear basin, would that
effectively terminate its membership in the Association and subsequently decrease the Association Estuary TN load by
50% of the current discharge allocation of 33,790 Ibs?
If the Town moves its entire discharge to another basin and ceases its discharge in the Neuse basin, we would modify its
permit accordingly. Once it loses its authorization to discharge in the Neuse, it is no longer eligible for membership in
the NRCA. The Town's TN allocation is linked to its individual permit, so it would be deducted from the NRCA limit when
the Town leaves. However, under the current rules, the Town would still hold its TN allocation and would have options
for what it does with that.
On the other hand, if the Town keeps its permit to discharge up to its 1.9 MGD at Outfall, its membership should not be
affected, nor should the NRCA's permit, including the Town's individual TN limit and the Association's group limit.
...if Town of Benson wished to maintain membership in the Association, is a second permitted discharge in another basin
even possible? Would they be able to keep their 1.9 MGD discharge to Hannah Creek and send treated effluent in excess
of 1.9 MGD to a second discharge in the Cape Fear basin?
I believe they could, as I've described above. But, again, this could change depending on what the Town proposes. I'm
speaking broadly here, and the details of the proposal could affect our response.
And from your earlier email, in case you havent' gotten answers already:
What is the definition in terms of cfs that makes a potential receiving stream effectively zero flow and not viable for
consideration? Rule 15A NCAC 02B .0206(d) prohibits new or expanding discharges if both the 7Q10 and 30Q2 flows
are zero. In practice, we consider zero flow to be anything less than 0.05 cfs. In particular, for a permitted flow of 3.75
MGD, is there a cfs threshold that must be exceeded? We don't consider the waste flow until we have first determined
i

whether the stream is zero -flow: if it's zero -flow, the permitted flow is irrelevant, as no discharge is allowed. If the
stream flow is greater than zero, we calculate the instream waste concentration (Qwaste / (Qwaste + Qstream) and use
that to calculate permit limits necessary to protect WQ standards in the stream. In effect, a discharge into barely -above -
zero -flow stream would have to meet the standards at end -of -pipe. We are preparing to request speculative limits, but
are trying to determine what discharge locations should be eliminated right out of the gate. Obviously, the list of
candidate streams should be quite a bit longer for a new 1.85 MGD discharge than for the 3.75 MGD option. Unless
other factors confound it, continuing to discharge the permitted 1.9 MGD to Hannah Creek should be to the Town's
advantage. Again, note that discharges in the Middle Cape Fear could be subject to nutrient limits in the coming years.
Let me know if you have other questions or want to discuss further. If I don't talk to you beforehand, I hope you have a
wonderful Thanksgiving and enjoy the long weekend!
— Mike T
Michael E. Templeton, P.E.
Wastewater Permitting Section
Division of Water Resources
Department of Environmental Quality
Office: Archdale Building, 9th Floor (925V)
512 North Salisbury Street, Raleigh, NC 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC 27699-1617
Office: 919-707-3603
[e-mail]
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect
the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. To accommodate these staffing
changes, all DEQ office locations are limiting public access to appointments only. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this
challenging time.
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Chris White [mailto:[e-mail]]
Sent: Thursday, November 18, 2021 8:59 AM
To: Templeton, Mike <[e-mail]>
Subject: RE: [External] RE: Town of Benson - EAA and possible discharge to Cape Fear instead of Neuse
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Mike,
Understand you were out of the office for a bit; hopefully you are catching back up.
Do you have an update on the questions below, especially discharging to two basins?
Chris White, PE
Sr. Project Manager / Engineer
[phone] x866 • Office
[phone] • Mobile
120 N. Boylan Ave.
Raleigh, NC 27603
Wooten
2

From: Templeton, Mike <[e-mail]>
Sent: Tuesday, October 12, 2021 12:53 PM
To: Chris White <[e-mail]>
Subject: RE: [External] RE: Town of Benson - EAA and possible discharge to Cape Fear instead of Neuse
Hi, Chris —
I haven't forgotten you. I'm checking on a couple of things, hope to get back to you shortly. Thanks.
— Mike T
Michael E. Templeton, P.E.
Wastewater Permitting Section
Division of Water Resources
Department of Environmental Quality
Office: Archdale Building, 9th Floor (925V)
512 North Salisbury Street, Raleigh, NC 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC 27699-1617
Office: 919-707-3603
[e-mail]
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect
the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. To accommodate these staffing
changes, all DEQ office locations are limiting public access to appointments only. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this
challenging time.
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Chris White [mailto:[e-mail]]
Sent: Friday, October 8, 2021 2:39 PM
To: Templeton, Mike <[e-mail]>
Subject: [External] RE: Town of Benson - EAA and possible discharge to Cape Fear instead of Neuse
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Mike,
I have an additional question regarding low -flow streams for the Benson discharge. What is the definition in terms of cfs
that makes a potential receiving stream effectively zero -flow and not viable for consideration? In particular, for a
permitted flow of 3.75 MGD, is there a cfs threshold that must be exceeded?
We are preparing to request speculative limits, but are trying to determine what discharge locations should be
eliminated right out of the gate.
Chris White, PE
,Jea iwd„uger / engineer
[phone] x866 • Office
[phone] • Mobile
120 N. Boylan Ave.
Raleigh, NC 27603
ooten
3

From: Chris White
Sent: Monday, October 4, 2021 5:19 PM
To: [e-mail]
Subject: Town of Benson - EAA and possible discharge to Cape Fear instead of Neuse
Good afternoon, Mike
I am putting together the Engineering Alternatives Analysis for the Town of Benson (NC0020389). Because Hannah Creek
is unlikely to be a viable option for increased discharge due to its low -flow, we are evaluating several options including
alternative discharge locations in both the Cape Fear and Neuse River Basins. From the Neuse River Compliance
Association (NCC000001), if Benson were to discharge all of its treated effluent to the Cape Fear basin, would that
effectively terminate its membership in the Association and subsequently decrease the Association Estuary TN load by
50% of the current discharge allocation of 33,790 Ibs?
Furthermore, if Town of Benson wished to maintain membership in the Association, is a second permitted discharge in
another basin even possible? Would they be able to keep their 1.9 MGD discharge to Hannah Creek and send treated
effluent in excess of 1.9 MGD to a second discharge in the Cape Fear basin?
I realize this isn't a common issue, but the plant is very close to the division of the two basins and the rapid growth of
the entire region (and the potential IBT issues) creates a fairly unique circumstance. I'm trying to capture the various
impacts of the different alternatives, especially ones that may present themselves if regionalization of water and/or
wastewater systems becomes an appealing undertaking for the Town.
Thank you for your assistance.
Chris White, PE
Sr. Project Manager/Engineer
[phone] x866 • Office
[phone] • Mobile
120 N. Boylan Ave.
Raleigh, NC 27603
ooten
4

Chris White
From: Hill, David A <[e-mail]>
Sent: Friday, December 10, 2021 7:59 AM
To: Chris White
Subject: Re: [External] Speculative limits request guidance
Follow Up Flag: Follow up
Flag Status: Flagged
Yes, POTW's can discharge to WS-IV waters. Thortons Creek is in the Cape Fear and we are not able to
consider new discharges until the current modeling study is finished, which be a year at the earliest.
David Hill
Environmental Specialist II
Industrial Permitting Unit
**Email preferred during this time*
NC DEQ / Division of Water Resources / Water Quality Permitting Section
NPDES Industrial Permitting Unit
919 707 3612 office
919 707 9000 main office
david.hiWncdenr.gov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Chris White <[e-mail]>
Sent: Thursday, December 9, 2021 10:43 AM
To: Hill, David A <[e-mail]>
Subject: RE: [External] Speculative limits request guidance
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
David,
Are speculative limits possible on waters classified as WS-IV? Specifically, Thortons Creek at NC-27
Thank you very much for the assistance provided thus far.
Chris White, PE
Sr. Project Manager/Engineer
[phone] x866 • Office
[phone] • Mobile
120 N. Boylan Ave.
Raleigh, NC 27603
Wooten
1

From: Hill, David A <[e-mail]>
Sent: Monday, December 6, 2021 9:34 AM
To: Chris White <[e-mail]>; Dowden, Doug <[e-mail]>
Cc: Montebello, Michael J <[e-mail]>
Subject: Re: [External] Speculative limits request guidance
Yes, we are unable to offer speculative limits for any swamp classified stream at this time. As for Stone Creek,
nothing jumps out at me which would preclude that stream for a discharge.
David Hill
Environmental Specialist II
Industrial Permitting Unit
**Email preferred during this time*
NC DEQ / Division of Water Resources / Water Quality Permitting Section
NPDES Industrial Permitting Unit
919 707 3612 office
919 707 9000 main office
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Chris White <[e-mail]>
Sent: Friday, December 3, 2021 10:25 AM
To: Hill, David A <[e-mail]>; Dowden, Doug <[e-mail]>
Cc: Montebello, Michael J <[e-mail]>
Subject: RE: [External] Speculative limits request guidance
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Thank you, David. This is very helpful. To discharge in the Cape Fear basin, we would cross Stony Run, Juniper Creek, and
Black River - all classified as C; Sw —to get to the Cape Fear River. Can you confirm the same methodology applies for
those waters and that new discharges aren't possible for those waters we'd cross due to the Sw classification?
It appears that we'll investigate Stone Creek as an alternative. While it is a Nutrient Sensitive Water and is in the Neuse
Basin, I did not see it on the 303d list. We'd look at Stone Creek where it crosses Adams Rd (Lat: 35.3602, Lon: -78.4760).
Are there any issues with that water as a potential discharge point for 1.85 mgd? I will submit the USGS low -flow request
form shortly.
Thank you for your help.
Chris White, PE
Sr. Project Manager/Engineer
[phone] x866 • Office
[phone] • Mobile
120 N. Boylan Ave.
Raleigh, NC 27603
Wooten
2

From: Hill, David A <[e-mail]>
Sent: Friday, December 3, 2021 6:53 AM
To: Dowden, Doug <[e-mail]>; Chris White <[e-mail]>
Cc: Montebello, Michael J <[e-mail]>
Subject: Re: [External] Speculative limits request guidance
Hello Chris,
Mingo Swamp has a supplementary classification of swamp. This supplementary classification allows the water
to exceed the normal freshwater criteria for dissolved oxygen and pH because of the natural conditions found
in swamp waters. The Division does not currently have a method for evaluating these criteria for new and
expanding discharges in swamp waters so a new discharge to Mingo Swamp is not possible at this time.
Hannah Creek is listed on our 303d list of impaired waters for dissolved oxygen and has been listed for
impairment since 2004. Impairment for dissolved oxygen precludes permitting any additional oxygen -
consuming wastes to the stream. We could potentially permit an expansion by freezing the mass -loading of
the discharge. For the Town of Benson, at the flow you're anticipating, this would cut the existing BOD and
ammonia limits almost in half. These would be very stringent limits as the facility already has 5/1 limits for
BOD/ammonia.
I bring these up so you aware of the issues before submitting the speculative limits request. We can always
explain further if needed. I'm also attaching the last 10 years of data from the LNBA coalition stations that
bracket the discharge and a link to the fact sheet from the facility's last permit renewal.
Facts
sheet:https://edocs.deq.nc.gov/WaterResources/DocView.aspx?id=1715272&dbid=0&repo=WaterResources
Sincerely,
David Hill
Environmental Specialist II
Industrial Permitting Unit
**Email preferred during this time*
NC DEQ / Division of Water Resources / Water Quality Permitting Section
NPDES Industrial Permitting Unit
919 707 3612 office
919 707 9000 main office
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Dowden, Doug <[e-mail]>
Sent: Thursday, December 2, 2021 12:44 PM
To: Chris White <[e-mail]>; Hill, David A <[e-mail]>
Cc: Montebello, Michael J <[e-mail]>
Subject: Re: [External] Speculative limits request guidance
3

Hi Chris,
David is out today, but I will speak with him friday about getting at least a preliminary response to you
by Monday. The dilution modeling and speculative limits, as you can expect are piling up. However,
you are ahead of the curve or the anticipated deluge of request.
David, please respond to Chris by Monday, thanks.
I have copied Mike Montebello on this email, since he manages the Municipal sector.
If you should have any questions and/or concerns please feel free to reach out to me at your earliest convenience.
Sincerely,
Douglas Dowden
Environmental Program Supervisor II
Division of Water Resources / Permitting
Department of Environmental Quality
Office: Archdale Building, 9th Floor (925Q)
512 North Salisbury Street, Raleigh, NC 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC 27699-1617
Office: 919-707-3605
[e-mail]
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect
the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. To accommodate these staffing
changes, all DEQ office locations are limiting public access to appointments only. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this
challenging time.
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Chris White <[e-mail]>
Sent: Thursday, December 2, 2021 11:18 AM
To: Dowden, Doug <[e-mail]>; Hill, David A <[e-mail]>
Subject: FW: [External] Speculative limits request guidance
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Doug/David,
Good morning. I'm preparing a letter to request speculative limits for the Town of Benson. I've received the USGS
response for low flow requests that each of you were copied on Oct 7 from John Weaver. How much detail or
background do I need to include in the letter? Also is it acceptable to scan the letter and email it to the two of you along
with the USGS low flow responses?
This particular project has a lot of uncommon aspects, including the preferred alternative of discharging to two basins
(Hannah Creek to the Neuse, and Mingo Swamp to the Cape Fear). I've confirmed with Mike Templeton that it is
possible to have a permit written that properly regulates both discharges. The Town will eventually need to address
Interbasin Transfer, so it is appealing to discharge to the Cape Fear basin. However, there are economical reasons to
maintain the existing discharge to the Neuse basin. Furthermore, knowing that a nutrient control strategy is being
developed for the Middle Cape Fear leaves some uncertainty about future requirements. So, there are a lot of moving
4

parts and we'd like to position the plant for easier future expansion, but need some of the uncertainties to shake out
before planning a long discharge line in either basin.
Do I need to explain the above paragraph within the request? We are planning to request speculative limits of 1.85 mgd
for Mingo Swamp for the 2-basin discharge option, and expanding the current Hannah Creek discharge to 3.25 mgd.
Please feel free to call if you think that would be easier to address my questions.
Chris White, PE
Sr. Project Manager/Engineer
[phone] x866 • Office
[phone] • Mobile
120 N. Boylan Ave.
Raleigh, NC 27603
ooten
From: Carl Scharfe <[e-mail]>
Sent: Friday, October 22, 2021 12:45 PM
To: Chris White <[e-mail]>
Subject: Fwd: [External] Speculative limits request guidance
Get Outlook for Android
From: Dowden, Doug <[e-mail]>
Sent: Friday, October 22, 2021 10:21:42 AM
To: Carl Scharfe <[e-mail]>
Cc: Hill, David A < >; Montebello, Michael J <[e-mail]>
Subject: Re: [External] Speculative limits request guidance
Hi Carl,
There is no doubt that our website can use some enhancements. We will work on that as time
permits. Request should be sent to myself and David Hill. David is our expert modeler and has an
extensive wealth of knowledge. David is copied on this email to expedite the request
Typically, speculative limits request come from the WWTP owner since NCDEQ only provides
speculative limits assessments / evaluations for POTWs. However we do recognize that consultants
are often acting at the bequest of their client, a POTW. With that said, in order to begin the process
we need the following from the requestor:
• Facility name,
• Owner name,
• Facility permit number(s),
• Facility address
• Flow request, from x MGD to Y MGD.
David, please let me know if I left anything out of this list. Thanks.
If you should have any questions and/or concerns please feel free to reach out to me at your earliest convenience.
Sincerely,
5

Douglas Dowden
Environmental Program Supervisor II
Division of Water Resources / Permitting
Department of Environmental Quality
Office: Archdale Building, 9th Floor (925Q)
512 North Salisbury Street, Raleigh, NC 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC 27699-1617
Office: 919-707-3605
[e-mail]
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect
the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. To accommodate these staffing
changes, all DEQ office locations are limiting public access to appointments only. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this
challenging time.
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Montebello, Michael J <[e-mail]>
Sent: Friday, October 22, 2021 10:08 AM
To: Dowden, Doug <[e-mail]>
Cc: Hill, David A <[e-mail]>
Subject: Fw: [External] Speculative limits request guidance
Doug,
This came in to MikeT and Cassidy from the Wooten Company. As a request for more info.
Tks
MikeM
From: Carl Scharfe <[e-mail]>
Sent: Thursday, October 21, 2021 11:46 AM
To: Kurtz, Cassidy <[e-mail]>; Templeton, Mike <[e-mail]>; Montebello, Michael
J <[e-mail]>
Subject: [External] Speculative limits request guidance
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Hi all:
Looking on the DEQ NPDES website portion, but do not really see requirements for a speculative limits
request. I assume USGS map showing the location and the flow to be discharged from the WWTP. In the
past it has been a page or two letter with a USGS map. Can one of you please guide me to what you
require? Do we submit it to NPDES branch or someone else?
Carl W Scharfe, PE
Project Manager/Senior Process Engineer
[phone] x837 • Office
[phone] • Mobile
[phone] • Fax
120 N. Boylan Ave.
6

Raleigh, NC 27603
Wooten

Chris White
From: Weaver, John C <[e-mail]>
Sent: Thursday, October 7, 2021 5:24 PM
To: Chris White
Cc: Hill, David A; [e-mail]; Montebello, Michael J; Dowden, Doug;
Albertin, Klaus P; Weaver, John C
Subject: USGS response to DWR USGS Low Flows request # 2021-149 (dated 2021/09/20) for
Hannah Creek Johnston County...RE: [EXTERNAL] Low -flow request approval
Follow Up Flag: Follow up
Flag Status: Flagged
Mr. White,
In response to your inquiry about the low -flow characteristics for a location on Hannah Creek adjacent a sewage
treatment facility northeast of Benson in southwestern Johnston County, the following information is provided:
A check of the low -flow files here at the USGS South Atlantic Water Science Center (Raleigh office) indicates previous
low -flow determinations for several locations on Hannah Creek in vicinity of the point of interest, identified by the
lat/long coordinates (35.3895, -78.5077) provided via email dated 09/20/2021 from the DWR USGS Low Flow portal
following your request submission. The most recent low -flow determinations being completed in April 1987, low -flow
characteristics for these locations were estimated based on transfer of flow characteristics from nearby index sites in
vicinity of the points of interest.
No USGS discharge records are known to exist for the point of interest.
In the absence of site -specific discharge records sufficient for a low -flow analysis, estimates of low -flow characteristics at
ungaged locations are determined by assessing a range in the low -flow yields (expressed as flow per square
mile drainage area, or cfsm) at nearby sites where estimates have previously been determined.
A basin delineation completed using the online USGS StreamStats application for North Carolina
(https://streamstats.usgs.gov/ss/) indicates the drainage area for the point of interest (StreamStats adjusted
coordinates 35.38953, -78.50770 NAD83) is 11.4 sqmi, which confirms the drainage area submitted as part of the
request information.
For streams in southwestern Johnston County, low -flow characteristics published by the USGS are provided in the
following reports:
(1) The first is a statewide report completed in the early 1990's. It is USGS Water -Supply Paper 2403, "Low -flow
characteristics of streams in North Carolina" (Giese and Mason, 1993). An online version of the report is available at
http://pubs.usgs.gov/wsp/2403/report.pdf. The report provides the low -flow characteristics (based on data through
1988) via regional relations and at -site values for sites with drainage basins between 1 and 400 sqmi and not considered
or known to be affected by regulation and/or diversions.
(2) The second is a basin -wide report for the Neuse River basin published in 1998. It is USGS Water -Resources
Investigations Report 98-4135, "Low -flow characteristics and discharge profiles for selected streams in the Neuse River
basin, North Carolina" (Weaver, 1998). The report is available online at
http://pubs.usgs.gov/wri/1998/4135/report.pdf. This report provides low -flow characteristics (based on data through
i

1996) for USGS continuous- and partial -record sites in the Neuse River basin where sufficient data was available for
analyses. However, the report does not provide statistical relations for estimating low -flow characteristics at ungaged
locations.
(3) The third is a basin -wide report for the Cape Fear River basin published in 2001. It is USGS Water -Resources
Investigations Report 01-4094, "Low -flow characteristics and discharge profiles for selected streams in the Cape Fear
River Basin, North Carolina, through 1998 " (Weaver and Pope, 2001). An online version of the report is available
through http://nc.water.usgs.gov/reports/wri014094/. The report provides the low -flow characteristics (based on data
through 1998) for continuous -record gaging stations and partial -record sites within the Cape Fear River basin. The
report also provides low -flow discharge profiles (7Q10, 30Q2, winter 7Q10, and 7Q2) for the Cape Fear River and
selected tributaries within the basin.
(4) The fourth is a statewide report published in March 2015. It is USGS Scientific Investigations Report 2015-5001,
"Low -flow characteristics and flow -duration statistics for selected USGS continuous -record streamgaging stations in
North Carolina through 2012" (Weaver, 2015). The report is available online at
http://pubs.usgs.gov/sir/2015/5001/. The report provides updated low -flow characteristics and flow -duration statistics
for 266 active (as of 2012 water year) and discontinued streamgages across the state where a minimum of 10 climatic
years discharge records were available for flow analyses.
Low -flow characteristics estimated for point of interest:
For the record: The low -flow request for this point of interest was paired with low -flow requests for two other points of
interest at (1) a downstream location on Hannah Creek in southeastern Johnston County, and (2) nearby Mingo Swamp
at the Johnston/Harnett County boundary south of Benson (Johnston County). The low -flow yields used for this point of
interest were likewise applied to the nearby point of interest on Mingo Swamp.
Inspection of the above -referenced reports indicates the presence of eleven (11) nearby selected USGS partial -record
sites (9) and continuous -record streamgages (2) across southwestern Johnston County and eastern Harnett County in
the general vicinity of the point of interest where low -flow characteristics were published. Among these 11 index sites,
the low -flow discharge yields for the indicated flow statistics are as follows:
Annual 7Q10 low -flow yields ==> from 0 to 0.0083 cfsm (average about 0.0016 cfsm, median about 0 cfsm) (zero flow at
8 of 11 index sites)
Annual 30Q2 low -flow yields ==> from 0 to 0.13 cfsm (average about 0.042 cfsm, median about 0.027 cfsm) (zero flow at
1 of 11 index sites)
Winter 7Q10 low -flow yields ==> from 0 to 0.073 cfsm (average about 0.026 cfsm, median about 0.019 cfsm) (zero flow
at 1 of 11 index sites)
Annual 7Q2 low -flow yields ==> from 0 to 0.069 cfsm (average about 0.017 cfsm, median about 0.011 cfsm) (zero flow at
2 of 11 index sites)
Average annual discharge yields ==> from 1.1 to 1.2 cfsm (both average and median about 1.2 cfsm)
Application of the above range in yields to the drainage area (11.4 sqmi) for the point of interest results in the following
estimated low -flow discharges:
Annual 7Q10 low -flow discharges ==> from 0 to 0.095 cfs (average about 0.018 cfs, median about 0 cfs) 4 rounded
down to zero flow
Annual 30Q2 low -flow discharges ==> from 0 to 1.5 cfs (average about 0.48 cfs, median about 0.31 cfs)
Winter 7Q10 low -flow discharges ==> from 0 to 0.83 cfs (average about 0.3 cfs, median about 0.22 cfs)
Annual 7Q2 low -flow discharges ==> from 0 to 0.79 cfs (average about 0.19 cfs, median about 0.13 cfs)
Average annual discharge discharges ==> from 12.5 to 13.7 cfs (both average and median about 13.7 cfs)
2

Please note the range of 7Q10 low -flow yields provided above indicates that streams across southern Johnston and
eastern Harnett County in the vicinity of the point of interest likely have very little to no potentials for sustained base
flows.
Please note:
(1) The estimated flows are provided in units of cubic feet per second (cfs).
(2) The low -flow yields provided above are rounded to 2 significant figures. Estimated low -flow discharges less than 1
cfs are rounded to 2 significant figures. If between 1 and 100 cfs, then rounded to 1 decimal place; if greater than 100,
then rounded to the nearest whole number (zero decimal places).
(3) The information provided in this message is based on a preliminary assessment and considered provisional, subject
to revision pending collection of future data and further analyses.
These provisional streamflow statistics are provided via the DWR USGS Low Flows cooperative agreement between
the USGS and the N.C. Department of Environmental Quality, Division of Water Resources.
Hope this information is helpful.
Thank you.
Curtis Weaver
J. Curtis Weaver, Hydrologist, PE Email: [e-mail]
USGS South Atlantic Water Science Center Online: https://www.usgs.gov/centers/sa-water
North Carolina - South Carolina - Georgia
3916 Sunset Ridge Road
Raleigh, NC 27607
Phone: [phone] // Fax: [phone]
From: Albertin, Klaus P <[e-mail]>
Sent: Monday, September 20, 2021 4:03 PM
To: [e-mail]
Cc: Albertin, Klaus P <[e-mail]>; Hill, David A <[e-mail]>; [e-mail];
Weaver, John C <[e-mail]>; Montebello, Michael J <[e-mail]>; Dowden, Doug
<[e-mail]>
Subject: [EXTERNAL] Low -flow request approval
This email has been received from outside of DOI - Use caution before clicking on links, opening attachments, or responding.
Your request has been approved and will be forwarded to USGS. A response from USGS usually takes 7 - 10 business
days.
3

Request Flow Statistic Approval
Request ID: 149
Requestor: Chris White
Requestor e-mail: cwhite q thewootencompany.com
Requestor Phone: [phone]
Local Government:
Public Water Supply:
Consultant: The Wooten Company
Contact: Chris White
Reason: Permit
River/Stream: Hannah Creek
Drainage Area (sq. mi.): 11.4
Latitude: 35.3895
Longitude: -78.5077
Other Information: Discharge point for permit NC0020389
Statististics: ["7010","30Q21
Approved by: Albertin, Klaus P
4

Chris White
From: Weaver, John C <[e-mail]>
Sent: Thursday, October 7, 2021 5:24 PM
To: Chris White
Cc: Hill, David A; [e-mail]; Montebello, Michael J; Dowden, Doug;
Albertin, Klaus P; Weaver, John C
Subject: USGS response to DWR USGS Low Flows request # 2021-150 (dated 2021/09/20) for
Hannah Creek Johnston County...RE: [EXTERNAL] Low -flow request approval
Follow Up Flag: Follow up
Flag Status: Flagged
Mr. White,
In response to your inquiry about the low -flow characteristics for a location at the mouth of Hannah Creek adjacent NC
Secondary Road 1009 (Devils Racetrack Road) approximately 0.7 mile north-northwest of Bentonville in southeastern
Johnston County, the following information is provided:
A check of the low -flow files here at the USGS South Atlantic Water Science Center (Raleigh office) does not indicate a
previous low -flow determination at or near the point of interest, identified by the lat/long coordinates (35.3595, -
78.2999) provided via email dated 09/20/2021 from the DWR USGS Low Flow portal following your request
submission. However, per Table 5 in USGS WRIR 98-4135 (Weaver, 1998; Neuse River basin -wide low -flow report), the
point of interest is located downstream from a USGS partial -record site on Hannah Creek near Bentonville (station id
02088266, NWIS drainage area 68.3 sqmi) with a USGS discharge record of 1 miscellaneous measurement obtained in
the 1955 water year.
No USGS discharge records are known to exist for the point of interest.
In the absence of site -specific discharge records sufficient for a low -flow analysis, estimates of low -flow characteristics at
ungaged locations are determined by assessing a range in the low -flow yields (expressed as flow per square
mile drainage area, or cfsm) at nearby sites where estimates have previously been determined.
A basin delineation completed using the online USGS StreamStats application for North Carolina
(https://streamstats.usgs.gov/ss/) indicates the drainage area for the point of interest (StreamStats adjusted
coordinates 35.35945, -78.29999 NAD83) is 64.3 sqmi, which confirms the drainage area submitted as part of the
request information.
For streams in the vicinity of southern Johnston County, low -flow characteristics published by the USGS are provided
in the following reports:
(1) The first is a statewide report completed in the early 1990's. It is USGS Water -Supply Paper 2403, "Low -flow
characteristics of streams in North Carolina" (Giese and Mason, 1993). An online version of the report is available at
http://pubs.usgs.gov/wsp/2403/report.pdf. The report provides the low -flow characteristics (based on data through
1988) via regional relations and at -site values for sites with drainage basins between 1 and 400 sqmi and not considered
or known to be affected by regulation and/or diversions.
(2) The second is a basin -wide report for the Neuse River basin published in 1998. It is USGS Water -Resources
Investigations Report 98-4135, "Low -flow characteristics and discharge profiles for selected streams in the Neuse River
1

basin, North Carolina" (Weaver, 1998). The report is available online at
http://pubs.usgs.gov/wri/1998/4135/report.pdf. This report provides low -flow characteristics (based on data through
1996) for USGS continuous- and partial -record sites in the Neuse River basin where sufficient data was available for
analyses. However, the report does not provide statistical relations for estimating low -flow characteristics at ungaged
locations.
(3) The third is a basin -wide report for the Cape Fear River basin published in 2001. It is USGS Water -Resources
Investigations Report 01-4094, "Low -flow characteristics and discharge profiles for selected streams in the Cape Fear
River Basin, North Carolina, through 1998 " (Weaver and Pope, 2001). An online version of the report is available
through http://nc.water.usgs.gov/reports/wri014094/. The report provides the low -flow characteristics (based on data
through 1998) for continuous -record gaging stations and partial -record sites within the Cape Fear River basin. The
report also provides low -flow discharge profiles (7Q10, 30Q2, winter 7Q10, and 7Q2) for the Cape Fear River and
selected tributaries within the basin.
(4) The fourth is a statewide report published in March 2015. It is USGS Scientific Investigations Report 2015-5001,
"Low -flow characteristics and flow -duration statistics for selected USGS continuous -record streamgaging stations in
North Carolina through 2012" (Weaver, 2015). The report is available online at
http://pubs.usgs.gov/sir/2015/5001/. The report provides updated low -flow characteristics and flow -duration statistics
for 266 active (as of 2012 water year) and discontinued streamgages across the state where a minimum of 10 climatic
years discharge records were available for flow analyses.
Low -flow characteristics estimated for point of interest:
Inspection of the above -referenced reports indicates the presence of eleven (11) nearby selected USGS partial -record
sites (8) and continuous -record streamgages (3) primarily across southern Johnston County in the general vicinity of the
point of interest where low -flow characteristics were published. Among these 11 index sites, the low -flow discharge
yields for the indicated flow statistics are as follows:
Annual 7Q10 low -flow yields ==> from 0 to 0.0084 cfsm (average about 0.0031 cfsm, median about 0.0037 cfsm) (zero
flow at 4 of 11 index sites)
Annual 30Q2 low -flow yields ==> from 0 to 0.12 cfsm (average about 0.054 cfsm, median about 0.056 cfsm) (zero flow at
2 of 11 index sites)
Winter 7Q10 low -flow yields ==> from 0 to 0.077 cfsm (average about 0.037 cfsm, median about 0.047 cfsm) (zero flow
at 2 of 11 index sites)
Annual 7Q2 low -flow yields ==> from 0 to 0.061 cfsm (average about 0.026 cfsm, median about 0.034 cfsm) (zero flow at
3 of 11 index sites)
Average annual discharge yields ==> from 0.98 to 1.2 cfsm (both average and median about 1.1 cfsm)
Application of the above range in yields to the drainage area (64.3 sqmi) for the point of interest results in the following
estimated low -flow discharges:
Annual 7Q10 low -flow discharges ==> from 0 to 0.54 cfs (average about 0.2 cfs, median about 0.24 cfs)
Annual 30Q2 low -flow discharges ==> from 0 to 7.7 cfs (average about 3.5 cfs, median about 3.6 cfs)
Winter 7Q10 low -flow discharges ==> from 0 to 5 cfs (average about 2.4 cfs, median about 3 cfs)
Annual 7Q2 low -flow discharges ==> from 0 to 3.9 cfs (average about 1.7 cfs, median about 2.2 cfs)
Average annual discharge discharges ==> from 63 to 77.2 cfs (both average and median about 70.7 cfs)
Please note:
(1) The estimated flows are provided in units of cubic feet per second (cfs).
2

(2) The low -flow yields provided above are rounded to 2 significant figures. Estimated low -flow discharges less than 1
cfs are rounded to 2 significant figures. If between 1 and 100 cfs, then rounded to 1 decimal place; if greater than 100,
then rounded to the nearest whole number (zero decimal places).
(3) The information provided in this message is based on a preliminary assessment and considered provisional, subject
to revision pending collection of future data and further analyses.
These provisional streamflow statistics are provided via the DWR USGS Low Flows cooperative agreement between
the USGS and the N.C. Department of Environmental Quality, Division of Water Resources.
Hope this information is helpful.
Thank you.
Curtis Weaver
J. Curtis Weaver, Hydrologist, PE Email: [e-mail]
USGS South Atlantic Water Science Center Online: https://www.usgs.gov/centers/sa-water
North Carolina - South Carolina - Georgia
3916 Sunset Ridge Road
Raleigh, NC 27607
Phone: [phone] // Fax: [phone]
From: Albertin, Klaus P <[e-mail]>
Sent: Monday, September 20, 2021 4:19 PM
To: [e-mail]
Cc: Albertin, Klaus P <[e-mail]>; Hill, David A <[e-mail]>; [e-mail];
Weaver, John C <[e-mail]>; Montebello, Michael J <[e-mail]>; Dowden, Doug
<[e-mail]>
Subject: [EXTERNAL] Low -flow request approval
This email has been received from outside of DOI - Use caution before clicking on links, opening attachments, or responding.
Your request has been approved and will be forwarded to USGS. A response from USGS usually takes 7 - 10 business
days.
Request Flow Statistic Approval
Request ID: 150
Requestor: Chris White
Requestor e-mail: [e-mail]
3

Requestor Phone: [phone]
Local Government:
Public Water Supply:
Consultant: The Wooten Company
Contact: Chris White
Reason: Permit
River/Stream: Hannah Creek
Drainage Area (sq. mi.): 64.3
Latitude: 35.3595
Longitude: -78.2999
Other Information:
Statististics: ["7010","3002"]
Approved by: Albertin, Klaus P
4

Chris White
From: Weaver, John C <[e-mail]>
Sent: Monday, December 13, 2021 2:05 PM
To: Chris White
Cc: Hill, David A; [e-mail]; Montebello, Michael J; Dowden, Doug;
Albertin, Klaus P; Weaver, John C
Subject: USGS response to DWR USGS Low Flows request # 2021-166 (dated 2021/12/03) for
Stone Creek Johnston County...RE: [EXTERNAL] Low -flow request approval
Follow Up Flag: Follow up
Flag Status: Flagged
Mr. White,
In response to your inquiry about the low -flow characteristics for a location on Stone Creek at NC Secondary Road 1744
(Adams Road) southeast of Benson in southern Johnston County, the following information is provided:
A check of the low -flow files here at the USGS South Atlantic Water Science Center (Raleigh office) does not indicate a
previous low -flow determination for the specific point of interest, identified by the lat/long coordinates (35.3602, -
78.4759) provided via email dated 12/03/2021 from the DWR USGS Low Flow portal following your request submission.
No USGS discharge records are known to exist for the point of interest.
In the absence of site -specific discharge records sufficient for a low -flow analysis, estimates of low -flow characteristics at
ungaged locations are determined by assessing a range in the low -flow yields (expressed as flow per square
mile drainage area, or cfsm) at nearby sites where estimates have previously been determined.
A basin delineation completed using the online USGS StreamStats application for North Carolina
(https://streamstats.usgs.gov/ss/) indicates the drainage area for the point of interest (StreamStats adjusted
coordinates 35.36014, -78.47588 NAD83) is 1.18 sqmi, which confirms the drainage area submitted as part of the
request information.
For streams in the vicinity of southern Johnston County, low -flow characteristics published by the USGS are provided
in the following reports:
(1) The first is a statewide report completed in the early 1990's. It is USGS Water -Supply Paper 2403, "Low -flow
characteristics of streams in North Carolina" (Giese and Mason, 1993). An online version of the report is available at
http://pubs.usgs.gov/wsp/2403/report.pdf. The report provides the low -flow characteristics (based on data through
1988) via regional relations and at -site values for sites with drainage basins between 1 and 400 sqmi and not considered
or known to be affected by regulation and/or diversions.
(2) The second is a basin -wide report for the Neuse River basin published in 1998. It is USGS Water -Resources
Investigations Report 98-4135, "Low -flow characteristics and discharge profiles for selected streams in the Neuse River
basin, North Carolina" (Weaver, 1998). The report is available online at
http://pubs.usgs.gov/wri/1998/4135/report.pdf. This report provides low -flow characteristics (based on data through
1996) for USGS continuous- and partial -record sites in the Neuse River basin where sufficient data was available for
analyses. However, the report does not provide statistical relations for estimating low -flow characteristics at ungaged
locations.
i

(3) The third is a basin -wide report for the Cape Fear River basin published in 2001. It is USGS Water -Resources
Investigations Report 01-4094, "Low -flow characteristics and discharge profiles for selected streams in the Cape Fear
River Basin, North Carolina, through 1998 " (Weaver and Pope, 2001). An online version of the report is available
through http://nc.water.usgs.gov/reports/wri014094/. The report provides the low -flow characteristics (based on data
through 1998) for continuous -record gaging stations and partial -record sites within the Cape Fear River basin. The
report also provides low -flow discharge profiles (7Q10, 30Q2, winter 7Q10, and 7Q2) for the Cape Fear River and
selected tributaries within the basin.
(4) The fourth is a statewide report published in March 2015. It is USGS Scientific Investigations Report 2015-5001,
"Low -flow characteristics and flow -duration statistics for selected USGS continuous -record streamgaging stations in
North Carolina through 2012" (Weaver, 2015). The report is available online at
http://pubs.usgs.gov/sir/2015/5001/. The report provides updated low -flow characteristics and flow -duration statistics
for 266 active (as of 2012 water year) and discontinued streamgages across the state where a minimum of 10 climatic
years discharge records were available for flow analyses.
Low -flow characteristics estimated for point of interest:
Inspection of the above -referenced reports indicates the presence of ten (10) nearby selected USGS partial -record sites
(7) and continuous -record streamgages (3) across southwestern Johnston County and eastern Harnett County in the
general vicinity of the point of interest where low -flow characteristics were published. Among these 10 index sites, the
low -flow discharge yields for the indicated flow statistics are as follows:
Annual 7Q10 low -flow yields ==> from 0 to 0.0071 cfsm (average about 0.0015 cfsm, median about 0 cfsm) (zero flow at
7 of 10 index sites)
Annual 30Q2 low -flow yields ==> from 0 to 0.13 cfsm (average about 0.039 cfsm, median about 0.031 cfsm) (zero flow at
1 of 10 index sites)
Winter 7Q10 low -flow yields ==> from 0 to 0.066 cfsm (average about 0.023 cfsm, median about 0.018 cfsm) (zero flow
at 1 of 10 index sites)
Annual 7Q2 low -flow yields ==> from 0 to 0.069 cfsm (average about 0.015 cfsm, median about 0.011 cfsm) (zero flow at
2 of 10 index sites)
Average annual discharge yields ==> from 1.1 to 1.2 cfsm (both average and median about 1.2 cfsm)
Application of the above range in yields to the drainage area (1.18 sqmi) for the point of interest results in the following
estimated low -flow discharges:
Annual 7Q10 low -flow discharges ==> from 0 to 0.0084 cfs (average about 0.0018 cfs, median about 0 cfs) 4 rounded
down to zero flow
Annual 30Q2 low -flow discharges ==> from 0 to 0.15 cfs (average about 0.046 cfs, median about 0.037 cfs)
Winter 7Q10 low -flow discharges ==> from 0 to 0.078 cfs (average about 0.027 cfs, median about 0.021 cfs)
Annual 7Q2 low -flow discharges ==> from 0 to 0.081 cfs (average about 0.018 cfs, median about 0.013 cfs) 4 rounded
down to zero flow
Average annual discharge discharges ==> from 1.3 to 1.4 cfs (both average and median about 1.4 cfs)
Please note the range of 7Q10 low -flow yields provided above indicates that streams across southern Johnston and
eastern Harnett County in the vicinity of the point of interest likely have very little to no potentials for sustained base
flows.
Please note:
2

(1) The estimated flows are provided in units of cubic feet per second (cfs).
(2) The low -flow yields provided above are rounded to 2 significant figures. Estimated low -flow discharges less than 1
cfs are rounded to 2 significant figures. If between 1 and 100 cfs, then rounded to 1 decimal place; if greater than 100,
then rounded to the nearest whole number (zero decimal places).
(3) The information provided in this message is based on a preliminary assessment and considered provisional, subject
to revision pending collection of future data and further analyses.
These provisional streamflow statistics are provided via the DWR USGS Low Flows cooperative agreement between
the USGS and the N.C. Department of Environmental Quality, Division of Water Resources.
Hope this information is helpful.
Thank you.
Curtis Weaver
J. Curtis Weaver, Hydrologist, PE Email: [e-mail]
USGS South Atlantic Water Science Center Online: https://www.usgs.gov/centers/sa-water
North Carolina - South Carolina - Georgia
3916 Sunset Ridge Road
Raleigh, NC 27607
Phone: [phone] // Fax: [phone]
From: Albertin, Klaus P <[e-mail]>
Sent: Friday, December 3, 2021 10:44 AM
To: [e-mail]
Cc: Albertin, Klaus P <[e-mail]>; Hill, David A <[e-mail]>; [e-mail];
Weaver, John C <[e-mail]>; Montebello, Michael J <[e-mail]>; Dowden, Doug
<[e-mail]>
Subject: [EXTERNAL] Low -flow request approval
This email has been received from outside of DOI - Use caution before clicking on links, opening attachments, or responding.
Your request has been approved and will be forwarded to USGS. A response from USGS usually takes 7 -10 business
days.
Request Flow Statistic Approval
Request ID: 166
Requestor: Chris White
Requestor e-mail: [e-mail]
3

Requestor Phone: [phone]
Local Government:
Public Water Supply:
Consultant: The Wooten Company
Contact: Chris White
Reason: Permit
River/Stream: Stone Creek
Drainage Area (sq. mi.): 1.18
Latitude: 35.3602
Longitude: -78.4759
Other Information: Southeast of Benson
Statististics: ["7010","3002"]
Approved by: Albertin, Klaus P
4

Chris White
From: Weaver, John C <[e-mail]>
Sent: Thursday, October 7, 2021 5:24 PM
To: Chris White
Cc: Hill, David A; [e-mail]; Montebello, Michael J; Dowden, Doug;
Albertin, Klaus P; Weaver, John C
Subject: USGS response to DWR USGS Low Flows request # 2021-151 (dated 2021/09/21) for
Mingo Swamp Harnett Johnston County...RE: [EXTERNAL] Low -flow request approval
Follow Up Flag: Follow up
Flag Status: Flagged
Mr. White,
In response to your inquiry about the low -flow characteristics for a location on Mingo Swamp at the railroad crossing
south of Benson at the Harnett County / Johnston County boundary, the following information is provided:
A check of the low -flow files here at the USGS South Atlantic Water Science Center (Raleigh office) indicates a previous
low -flow determination for a downstream location (approximately 1.3 miles) on Mingo Swamp below the point of
interest, identified by the lat/long coordinates (35.3641, -78.5628) provided via email dated 09/21/2021 from the DWR
USGS Low Flow portal following your request submission. Completed in March 1974, low -flow characteristics at the
downstream location were estimated based on transfer of flow characteristics from two nearby index sites on Mingo
Swamp in vicinity of the point of interest.
No USGS discharge records are known to exist for the point of interest.
In the absence of site -specific discharge records sufficient for a low -flow analysis, estimates of low -flow characteristics at
ungaged locations are determined by assessing a range in the low -flow yields (expressed as flow per square
mile drainage area, or cfsm) at nearby sites where estimates have previously been determined.
A basin delineation completed using the online USGS StreamStats application for North Carolina
(https://streamstats.usgs.gov/ss/) indicates the drainage area for the point of interest (StreamStats adjusted
coordinates 35.36410, -78.56284 NAD83) is 12.7 sqmi, which confirms the drainage area submitted as part of the
request information.
For streams in eastern Harnett County and southwestern Johnston County, low -flow characteristics published by
the USGS are provided in the following reports:
(1) The first is a statewide report completed in the early 1990's. It is USGS Water -Supply Paper 2403, "Low -flow
characteristics of streams in North Carolina" (Giese and Mason, 1993). An online version of the report is available at
http://pubs.usgs.gov/wsp/2403/report.pdf. The report provides the low -flow characteristics (based on data through
1988) via regional relations and at -site values for sites with drainage basins between 1 and 400 sqmi and not considered
or known to be affected by regulation and/or diversions.
(2) The second is a basin -wide report for the Neuse River basin published in 1998. It is USGS Water -Resources
Investigations Report 98-4135, "Low -flow characteristics and discharge profiles for selected streams in the Neuse River
basin, North Carolina" (Weaver, 1998). The report is available online at
http://pubs.usgs.gov/wri/1998/4135/report.pdf. This report provides low -flow characteristics (based on data through
i

1996) for USGS continuous- and partial -record sites in the Neuse River basin where sufficient data was available for
analyses. However, the report does not provide statistical relations for estimating low -flow characteristics at ungaged
locations.
(3) The third is a basin -wide report for the Cape Fear River basin published in 2001. It is USGS Water -Resources
Investigations Report 01-4094, "Low -flow characteristics and discharge profiles for selected streams in the Cape Fear
River Basin, North Carolina, through 1998 " (Weaver and Pope, 2001). An online version of the report is available
through http://nc.water.usgs.gov/reports/wri014094/. The report provides the low -flow characteristics (based on data
through 1998) for continuous -record gaging stations and partial -record sites within the Cape Fear River basin. The
report also provides low -flow discharge profiles (7Q10, 30Q2, winter 7Q10, and 7Q2) for the Cape Fear River and
selected tributaries within the basin.
(4) The fourth is a statewide report published in March 2015. It is USGS Scientific Investigations Report 2015-5001,
"Low -flow characteristics and flow -duration statistics for selected USGS continuous -record streamgaging stations in
North Carolina through 2012" (Weaver, 2015). The report is available online at
http://pubs.usgs.gov/sir/2015/5001/. The report provides updated low -flow characteristics and flow -duration statistics
for 266 active (as of 2012 water year) and discontinued streamgages across the state where a minimum of 10 climatic
years discharge records were available for flow analyses.
Low -flow characteristics estimated for point of interest:
For the record: The low -flow request for this point of interest was paired with low -flow requests for two other points of
interest at (1) nearby Hannah Creek adjacent a sewage treatment facility northeast of Benson, and (2) a downstream
location on Hannah Creek in southeastern Johnston County. The low -flow yields used for this point of interest were
likewise applied to the nearby point of interest on Hannah Creek northeast of Benson.
Inspection of the above -referenced reports indicates the presence of eleven (11) nearby selected USGS partial -record
sites (9) and continuous -record streamgages (2) across southwestern Johnston County and eastern Harnett County in
the general vicinity of the point of interest where low -flow characteristics were published. Among these 11 index sites,
the low -flow discharge yields for the indicated flow statistics are as follows:
Annual 7Q10 low -flow yields ==> from 0 to 0.0083 cfsm (average about 0.0016 cfsm, median about 0 cfsm) (zero flow at
8 of 11 index sites)
Annual 30Q2 low -flow yields ==> from 0 to 0.13 cfsm (average about 0.042 cfsm, median about 0.027 cfsm) (zero flow at
1 of 11 index sites)
Winter 7Q10 low -flow yields ==> from 0 to 0.073 cfsm (average about 0.026 cfsm, median about 0.019 cfsm) (zero flow
at 1 of 11 index sites)
Annual 7Q2 low -flow yields ==> from 0 to 0.069 cfsm (average about 0.017 cfsm, median about 0.011 cfsm) (zero flow at
2 of 11 index sites)
Average annual discharge yields ==> from 1.1 to 1.2 cfsm (both average and median about 1.2 cfsm)
Application of the above range in yields to the drainage area (11.4 sqmi) for the point of interest results in the following
estimated low -flow discharges:
Annual 7Q10 low -flow discharges ==> from 0 to 0.11 cfs (average about 0.02 cfs, median about 0 cfs) 4 rounded down
to zero flow
Annual 30Q2 low -flow discharges ==> from 0 to 1.7 cfs (average about 0.53 cfs, median about 0.34 cfs)
Winter 7Q10 low -flow discharges ==> from 0 to 0.93 cfs (average about 0.33 cfs, median about 0.24 cfs)
Annual 7Q2 low -flow discharges ==> from 0 to 0.88 cfs (average about 0.22 cfs, median about 0.14 cfs)
Average annual discharge discharges ==> from 14 to 15.2 cfs (both average and median about 15.2 cfs)
2

Please note the range of 7Q10 low -flow yields provided above indicates that streams across southern Johnston and
eastern Harnett County in the vicinity of the point of interest likely have very little to no potentials for sustained base
flows.
Please note:
(1) The estimated flows are provided in units of cubic feet per second (cfs).
(2) The low -flow yields provided above are rounded to 2 significant figures. Estimated low -flow discharges less than 1
cfs are rounded to 2 significant figures. If between 1 and 100 cfs, then rounded to 1 decimal place; if greater than 100,
then rounded to the nearest whole number (zero decimal places).
(3) The information provided in this message is based on a preliminary assessment and considered provisional, subject
to revision pending collection of future data and further analyses.
These provisional streamflow statistics are provided via the DWR USGS Low Flows cooperative agreement between
the USGS and the N.C. Department of Environmental Quality, Division of Water Resources.
Hope this information is helpful.
Thank you.
Curtis Weaver
J. Curtis Weaver, Hydrologist, PE Email: [e-mail]
USGS South Atlantic Water Science Center Online: https://www.usgs.gov/centers/sa-water
North Carolina - South Carolina - Georgia
3916 Sunset Ridge Road
Raleigh, NC 27607
Phone: [phone] // Fax: [phone]
From: Albertin, Klaus P <[e-mail]>
Sent: Tuesday, September 21, 2021 10:16 AM
To: [e-mail]
Cc: Albertin, Klaus P <[e-mail]>; Hill, David A <[e-mail]>; [e-mail];
Weaver, John C <[e-mail]>; Montebello, Michael J <[e-mail]>; Dowden, Doug
<[e-mail]>
Subject: [EXTERNAL] Low -flow request approval
This email has been received from outside of DOI - Use caution before clicking on links, opening attachments, or responding.
Your request has been approved and will be forwarded to USGS. A response from USGS usually takes 7 - 10 business
days.
3

Request Flow Statistic Approval
Request ID: 151
Requestor: Chris White
Requestor e-mail: cwhite q thewootencompany.com
Requestor Phone: [phone]
Local Government:
Public Water Supply:
Consultant: The Wooten Company
Contact: Chris White
Reason: Permit
River/Stream: Mingo Swamp
Drainage Area (sq. mi.): 12.7
Latitude: 35.3641
Longitude: -78.5628
Other Information:
Statististics: ["7010","30Q21
Approved by: Albertin, Klaus P
4

Chris White
From: Weaver, John C <[e-mail]>
Sent: Monday, December 13, 2021 4:50 PM
To: Chris White
Cc: Hill, David A; [e-mail]; Montebello, Michael J; Dowden, Doug;
Albertin, Klaus P; Weaver, John C
Subject: USGS response to DWR USGS Low Flows request # 2022-168 (dated 2021/12/09) for
Thorntons Creek Harnett County...RE: [EXTERNAL] Low -flow request approval
Follow Up Flag: Follow up
Flag Status: Flagged
Mr. White,
In response to your inquiry about the low -flow characteristics for a location on Thorntons Creek at N.C. Highway 27 at
Coats in eastern Harnett County, the following information is provided:
A check of the low -flow files here at the USGS South Atlantic Water Science Center (Raleigh office) does not indicate a
previous low -flow determination for the specific point of interest, identified by the lat/long coordinates (35.41355, -
78.69370) provided via email dated 12/09/2021 from the DWR USGS Low Flow portal following your request submission.
No USGS discharge records are known to exist for the point of interest.
In the absence of site -specific discharge records sufficient for a low -flow analysis, estimates of low -flow characteristics at
ungaged locations are determined by assessing a range in the low -flow yields (expressed as flow per square
mile drainage area, or cfsm) at nearby sites where estimates have previously been determined.
A basin delineation completed using the online USGS StreamStats application for North Carolina
(https://streamstats.usgs.gov/ss/) indicates the drainage area for the point of interest (StreamStats adjusted
coordinates 35.41355, -78.69367 NAD83) is 2.23 sqmi, which confirms the drainage area submitted as part of the
request information.
For streams in the vicinity of eastern Harnett County, low -flow characteristics published by the USGS are provided in
the following reports:
(1) The first is a statewide report completed in the early 1990's. It is USGS Water -Supply Paper 2403, "Low -flow
characteristics of streams in North Carolina" (Giese and Mason, 1993). An online version of the report is available at
http://pubs.usgs.gov/wsp/2403/report.pdf. The report provides the low -flow characteristics (based on data through
1988) via regional relations and at -site values for sites with drainage basins between 1 and 400 sqmi and not considered
or known to be affected by regulation and/or diversions.
(2) The second is a basin -wide report for the Neuse River basin published in 1998. It is USGS Water -Resources
Investigations Report 98-4135, "Low -flow characteristics and discharge profiles for selected streams in the Neuse River
basin, North Carolina" (Weaver, 1998). The report is available online at
http://pubs.usgs.gov/wri/1998/4135/report.pdf. This report provides low -flow characteristics (based on data through
1996) for USGS continuous- and partial -record sites in the Neuse River basin where sufficient data was available for
analyses. However, the report does not provide statistical relations for estimating low -flow characteristics at ungaged
locations.
i

(3) The third is a basin -wide report for the Cape Fear River basin published in 2001. It is USGS Water -Resources
Investigations Report 01-4094, "Low -flow characteristics and discharge profiles for selected streams in the Cape Fear
River Basin, North Carolina, through 1998 " (Weaver and Pope, 2001). An online version of the report is available
through http://nc.water.usgs.gov/reports/wri014094/. The report provides the low -flow characteristics (based on data
through 1998) for continuous -record gaging stations and partial -record sites within the Cape Fear River basin. The
report also provides low -flow discharge profiles (7Q10, 30Q2, winter 7Q10, and 7Q2) for the Cape Fear River and
selected tributaries within the basin.
(4) The fourth is a statewide report published in March 2015. It is USGS Scientific Investigations Report 2015-5001,
"Low -flow characteristics and flow -duration statistics for selected USGS continuous -record streamgaging stations in
North Carolina through 2012" (Weaver, 2015). The report is available online at
http://pubs.usgs.gov/sir/2015/5001/. The report provides updated low -flow characteristics and flow -duration statistics
for 266 active (as of 2012 water year) and discontinued streamgages across the state where a minimum of 10 climatic
years discharge records were available for flow analyses.
Low -flow characteristics estimated for point of interest:
For the record: The low -flow request for this point of interest is near another point of interest on Juniper Creek at Erwin
for which a separate low -flow request (#2022-167) was also submitted in early December 2021. The low -flow yields
used for this point of interest were likewise applied to the nearby point of interest on Juniper Creek.
Inspection of the above -referenced reports indicates the presence of twelve (12) nearby selected USGS partial -record
sites (10) and continuous -record streamgages (2) across southwestern Johnston County and eastern Harnett County in
the general vicinity of the point of interest where low -flow characteristics were published. Among these 12 index sites,
the low -flow discharge yields for the indicated flow statistics are as follows:
Annual 7Q10 low -flow yields ==> from 0 to 0.0071 cfsm (average about 0.0008 cfsm, median about 0 cfsm) (zero flow at
9 of 12 index sites)
Annual 30Q2 low -flow yields ==> from 0 to 0.13 cfsm (average about 0.038 cfsm, median about 0.024 cfsm) (zero flow at
1 of 12 index sites)
Winter 7Q10 low -flow yields ==> from 0 to 0.066 cfsm (average about 0.021 cfsm, median about 0.018 cfsm) (zero flow
at 1 of 12 index sites)
Annual 7Q2 low -flow yields ==> from 0 to 0.069 cfsm (average about 0.014 cfsm, median about 0.0091 cfsm) (zero flow
at 3 of 12 index sites)
Average annual discharge yields ==> from 1.1 to 1.2 cfsm (both average and median about 1.2 cfsm)
Application of the above range in yields to the drainage area (2.23 sqmi) for the point of interest results in the following
estimated low -flow discharges:
Annual 7Q10 low -flow discharges ==> from 0 to 0.016 cfs (average about 0.0018 cfs, median about 0 cfs) 4 zero flow
Annual 30Q2 low -flow discharges ==> from 0 to 0.29 cfs (average about 0.085 cfs, median about 0.054 cfs)
Winter 7Q10 low -flow discharges ==> from 0 to 0.15 cfs (average about 0.047 cfs, median about 0.04 cfs)
Annual 7Q2 low -flow discharges ==> from 0 to 0.15 cfs (average about 0.031 cfs, median about 0.02 cfs) 4 rounded
down to zero flow
Average annual discharge discharges ==> from 2.5 to 2.7 cfs (both average and median about 2.7 cfs)
Please note the range of 7Q10 low -flow yields provided above indicates that streams across southern Johnston and
eastern Harnett County in the vicinity of the point of interest likely have very little to no potentials for sustained base
flows.
2

Please note:
(1) The estimated flows are provided in units of cubic feet per second (cfs).
(2) The low -flow yields provided above are rounded to 2 significant figures. Estimated low -flow discharges less than 1
cfs are rounded to 2 significant figures. If between 1 and 100 cfs, then rounded to 1 decimal place; if greater than 100,
then rounded to the nearest whole number (zero decimal places).
(3) The information provided in this message is based on a preliminary assessment and considered provisional, subject
to revision pending collection of future data and further analyses.
These provisional streamflow statistics are provided via the DWR USGS Low Flows cooperative agreement between
the USGS and the N.C. Department of Environmental Quality, Division of Water Resources.
Hope this information is helpful.
Thank you.
Curtis Weaver
3. Curtis Weaver, Hydrologist, PE Email: [e-mail]
USGS South Atlantic Water Science Center Online: https://www.usgs.gov/centers/sa-water
North Carolina - South Carolina - Georgia
3916 Sunset Ridge Road
Raleigh, NC 27607
Phone: [phone] // Fax: [phone]
From: Albertin, Klaus P <[e-mail]>
Sent: Thursday, December 9, 2021 2:17 PM
To: [e-mail]
Cc: Albertin, Klaus P <[e-mail]>; Hill, David A <[e-mail]>; [e-mail];
Weaver, John C <[e-mail]>; Montebello, Michael J <[e-mail]>; Dowden, Doug
<[e-mail]>
Subject: [EXTERNAL] Low -flow request approval
This email has been received from outside of DOI - Use caution before clicking on links, opening attachments, or responding.
Your request has been approved and will be forwarded to USGS. A response from USGS usually takes 7 - 10 business
days.
Request Flow Statistic Approval
Request ID: 168
3

Requestor: Chris White
Requestor e-mail: [e-mail]
Requestor Phone: [phone]
Local Government:
Public Water Supply:
Consultant: The Wooten Company
Contact: Chris White
Reason: Potential Discharge
River/Stream: Thortons Creek
Drainage Area (sq. mi.): 2.23
Latitude: 35.41355
Longitude: -78.69370
Other Information:
Statististics: ["7010","30Q21
Approved by: Albertin, Klaus P
4

Chris White
From: Weaver, John C <[e-mail]>
Sent: Monday, December 13, 2021 4:33 PM
To: Chris White
Cc: Hill, David A; [e-mail]; Montebello, Michael J; Dowden, Doug;
Albertin, Klaus P; Weaver, John C
Subject: USGS response to DWR USGS Low Flows request # 2022-167 (dated 2021/12/07) for
Juniper Creek Harnett County...RE: [EXTERNAL] Low -flow request approval
Follow Up Flag: Follow up
Flag Status: Flagged
Mr. White,
In response to your inquiry about the low -flow characteristics for a location on Juniper Creek immediately upstream
from Stewart Creek at U.S. Highway 421 at Erwin in eastern Harnett County, the following information is provided:
For the record: Inspection of the streams layers on the USGS topographical map as well as the USGS StreamStats
application for the area of interest indicates that Stewart Creek merges with Juniper Creek at U.S. Highway 421. Based
on the location coordinates provided with information submitted for the low -flow request, the point of interest is
interpreted to be Juniper Creek just immediately upstream from Stewart Creek at the highway crossing.
A check of the low -flow files here at the USGS South Atlantic Water Science Center (Raleigh office) indicates previous
low -flow determinations for several locations on Stewart Creek in vicinity of the point of interest, identified by the
lat/long coordinates (35.34587, -78.68479) provided via email dated 12/07/2021 from the DWR USGS Low Flow portal
following your request submission. Completed in the mid and late 1970's, the low -flow characteristics for these
locations were estimated based on transfer of flow characteristics from nearby index sites in vicinity of the points of
interest.
No USGS discharge records are known to exist for the point of interest.
In the absence of site -specific discharge records sufficient for a low -flow analysis, estimates of low -flow characteristics at
ungaged locations are determined by assessing a range in the low -flow yields (expressed as flow per square
mile drainage area, or cfsm) at nearby sites where estimates have previously been determined.
A basin delineation completed using the online USGS StreamStats application for North Carolina
(https://streamstats.usgs.gov/ss/) indicates the drainage area for the point of interest (StreamStats adjusted
coordinates 35.34586, -78.68487 NAD83) is 4.04 sqmi, which confirms the drainage area submitted as part of the
request information.
For streams in the vicinity of eastern Harnett County, low -flow characteristics published by the USGS are provided in
the following reports:
(1) The first is a statewide report completed in the early 1990's. It is USGS Water -Supply Paper 2403, "Low -flow
characteristics of streams in North Carolina" (Giese and Mason, 1993). An online version of the report is available at
http://pubs.usgs.gov/wsp/2403/report.pdf. The report provides the low -flow characteristics (based on data through
1988) via regional relations and at -site values for sites with drainage basins between 1 and 400 sqmi and not considered
or known to be affected by regulation and/or diversions.
i

(2) The second is a basin -wide report for the Neuse River basin published in 1998. It is USGS Water -Resources
Investigations Report 98-4135, "Low -flow characteristics and discharge profiles for selected streams in the Neuse River
basin, North Carolina" (Weaver, 1998). The report is available online at
http://pubs.usgs.gov/wri/1998/4135/report.pdf. This report provides low -flow characteristics (based on data through
1996) for USGS continuous- and partial -record sites in the Neuse River basin where sufficient data was available for
analyses. However, the report does not provide statistical relations for estimating low -flow characteristics at ungaged
locations.
(3) The third is a basin -wide report for the Cape Fear River basin published in 2001. It is USGS Water -Resources
Investigations Report 01-4094, "Low -flow characteristics and discharge profiles for selected streams in the Cape Fear
River Basin, North Carolina, through 1998 " (Weaver and Pope, 2001). An online version of the report is available
through http://nc.water.usgs.gov/reports/wri014094/. The report provides the low -flow characteristics (based on data
through 1998) for continuous -record gaging stations and partial -record sites within the Cape Fear River basin. The
report also provides low -flow discharge profiles (7Q10, 30Q2, winter 7Q10, and 7Q2) for the Cape Fear River and
selected tributaries within the basin.
(4) The fourth is a statewide report published in March 2015. It is USGS Scientific Investigations Report 2015-5001,
"Low -flow characteristics and flow -duration statistics for selected USGS continuous -record streamgaging stations in
North Carolina through 2012" (Weaver, 2015). The report is available online at
http://pubs.usgs.gov/sir/2015/5001/. The report provides updated low -flow characteristics and flow -duration statistics
for 266 active (as of 2012 water year) and discontinued streamgages across the state where a minimum of 10 climatic
years discharge records were available for flow analyses.
Low -flow characteristics estimated for point of interest:
For the record: The low -flow request for this point of interest is near another point of interest on Thorntons Creek at
Coats for which a separate low -flow request (#2022-167) was also submitted in early December 2021. The low -flow
yields used for this point of interest were likewise applied to the nearby point of interest on Thorntons Creek.
Inspection of the above -referenced reports indicates the presence of twelve (12) nearby selected USGS partial -record
sites (10) and continuous -record streamgages (2) across southwestern Johnston County and eastern Harnett County in
the general vicinity of the point of interest where low -flow characteristics were published. Among these 12 index sites,
the low -flow discharge yields for the indicated flow statistics are as follows:
Annual 7Q10 low -flow yields ==> from 0 to 0.0071 cfsm (average about 0.0008 cfsm, median about 0 cfsm) (zero flow at
9 of 12 index sites)
Annual 30Q2 low -flow yields ==> from 0 to 0.13 cfsm (average about 0.038 cfsm, median about 0.024 cfsm) (zero flow at
1 of 12 index sites)
Winter 7Q10 low -flow yields ==> from 0 to 0.066 cfsm (average about 0.021 cfsm, median about 0.018 cfsm) (zero flow
at 1 of 12 index sites)
Annual 7Q2 low -flow yields ==> from 0 to 0.069 cfsm (average about 0.014 cfsm, median about 0.0091 cfsm) (zero flow
at 3 of 12 index sites)
Average annual discharge yields ==> from 1.1 to 1.2 cfsm (both average and median about 1.2 cfsm)
Application of the above range in yields to the drainage area (4.04 sqmi) for the point of interest results in the following
estimated low -flow discharges:
Annual 7Q10 low -flow discharges ==> from 0 to 0.029 cfs (average about 0.0032 cfs, median about 0 cfs) 4 zero flow
Annual 30Q2 low -flow discharges ==> from 0 to 0.53 cfs (average about 0.15 cfs, median about 0.097 cfs)
Winter 7Q10 low -flow discharges ==> from 0 to 0.27 cfs (average about 0.085 cfs, median about 0.073 cfs)
2

Annual 7Q2 low -flow discharges ==> from 0 to 0.28 cfs (average about 0.057 cfs, median about 0.037 cfs)
Average annual discharge discharges ==> from 4.4 to 4.8 cfs (both average and median about 4.8 cfs)
Please note the range of 7Q10 low -flow yields provided above indicates that streams across southern Johnston and
eastern Harnett County in the vicinity of the point of interest likely have very little to no potentials for sustained base
flows.
Please note:
(1) The estimated flows are provided in units of cubic feet per second (cfs).
(2) The low -flow yields provided above are rounded to 2 significant figures. Estimated low -flow discharges less than 1
cfs are rounded to 2 significant figures. If between 1 and 100 cfs, then rounded to 1 decimal place; if greater than 100,
then rounded to the nearest whole number (zero decimal places).
(3) The information provided in this message is based on a preliminary assessment and considered provisional, subject
to revision pending collection of future data and further analyses.
These provisional streamflow statistics are provided via the DWR USGS Low Flows cooperative agreement between
the USGS and the N.C. Department of Environmental Quality, Division of Water Resources.
Hope this information is helpful.
Thank you.
Curtis Weaver
J. Curtis Weaver, Hydrologist, PE Email; [e-mail]
USGS South Atlantic Water Science Center Online: https://www.usgs.gov/centers/sa-water
North Carolina - South Carolina - Georgia
3916 Sunset Ridge Road
Raleigh, NC 27607
Phone: [phone] // Fax: [phone]
From: Albertin, Klaus P <[e-mail]>
Sent: Tuesday, December 7, 2021 10:27 AM
To: [e-mail]
Cc: Albertin, Klaus P <[e-mail]>; Hill, David A <[e-mail]>; [e-mail];
Weaver, John C <[e-mail]>; Montebello, Michael J <[e-mail]>; Dowden, Doug
<[e-mail]>
Subject: [EXTERNAL] Low -flow request approval
This email has been received from outside of DOI - Use caution before clicking on links, opening attachments, or responding.
3

Your request has been approved and will be forwarded to USGS. A response from USGS usually takes 7 -10 business
days.
Request Flow Statistic Approval
Request ID: 167
Requestor: Chris White
Requestor e-mail: [e-mail]
Requestor Phone: [phone]
Local Government:
Public Water Supply:
Consultant: The Wooten Company
Contact: Chris White
Reason: Permit
River/Stream: Juniper Creek
Drainage Area (sq. mi.): 4.04
Latitude: 35.34587
Longitude: -78.68479
Other Information: Juniper Creek at US 421
Statististics: ["7010","30Q21
Approved by: Albertin, Klaus P
4

Chris White
From: Chris White
Sent: Wednesday, December 22, 2021 9:55 AM
To: Dowden, Doug; Hill, David A
Subject: Speculative Limits Request for Benson WWTP - New Discharge Location
Attachments: Benson WWTP Neuse Discharge Proposed.JPG; Benson WWTP Proposed Neuse
Discharge at Guin Rd.JPG
Gentlemen,
Referencing our ongoing discussions regarding expansion of the Benson Wastewater Treatment Plant and an additional
discharge location for flows in excess of its current Hannah Creek discharge location, it is hereby requested that
speculative effluent limitations be provided for the following.
Town of Benson, NC
Benson Wastewater Treatment Facility
770 Hannah Creek Road (south of 1-95)
Four Oaks
Johnston County
Permit NC0020389
Permit NCC000001 (Neuse River Compliance Association)
Maintain existing permitted discharge at Hannah Creek of 1.9 MGD
Request new additional permitted discharge to Neuse River of 1.85 MGD
Lat: 35.4274, -78.3351
Graphics of location attached
We have exhausted options to potential discharge locations closer to the facility. These options were eliminated due to
being classified as Swamp waters, having low flow characteristics, or by being in the Cape Fear River Basin (due to the
current development of a nutrient control strategy for the Middle Cape Fear). If modeling efforts are completed that
alleviate conditions that eliminated these options, we intend to revisit these options if time allows to develop another
Engineering Alternative Analysis.
I assume that due to the nature of social distancing and many people working remotely from their offices that this email
request will suffice. Please let me know if I should submit this request in another format.
Thank you.
Chris White, PE
Sr. Project Manager/Engineer
[phone] x866 • Office
[phone] • Mobile
120 N. Boylan Ave.
Raleigh, NC 27603
Wooten
1

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Chris White
From: Dowden, Doug <[e-mail]>
Sent: Wednesday, December 22, 2021 10:15 AM
To: Chris White; Hill, David A
Cc: Montebello, Michael J
Subject: Re: [External] Speculative Limits Request for Benson WWTP - New Discharge Location
Hi Chris,
David will put the request in the cue. He is working on a couple of other projects today and then is out
through next week, so he will get back to you after the first with an eta on your request.
If you should have any questions and/or concerns please feel free to reach out to me at your earliest convenience.
Sincerely,
Douglas Dowden
Environmental Program Supervisor II
Division of Water Resources / Permitting
Department of Environmental Quality
Office: Archdale Building, 9th Floor (925Q)
512 North Salisbury Street, Raleigh, NC 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC 27699-1617
Office: 919-707-3605
[e-mail]
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect
the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. To accommodate these staffing
changes, all DEQ office locations are limiting public access to appointments only. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this
challenging time.
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Chris White <[e-mail]>
Sent: Wednesday, December 22, 2021 9:55 AM
To: Dowden, Doug <[e-mail]>; Hill, David A <[e-mail]>
Subject: [External] Speculative Limits Request for Benson WWTP - New Discharge Location
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Gentlemen,
Referencing our ongoing discussions regarding expansion of the Benson Wastewater Treatment Plant and an additional
discharge location for flows in excess of its current Hannah Creek discharge location, it is hereby requested that
speculative effluent limitations be provided for the following.
Town of Benson, NC
Benson Wastewater Treatment Facility
1

770 Hannah Creek Road (south of 1-95)
Four Oaks
Johnston County
Permit NC0020389
Permit NCC000001 (Neuse River Compliance Association)
Maintain existing permitted discharge at Hannah Creek of 1.9 MGD
Request new additional permitted discharge to Neuse River of 1.85 MGD
Lat: 35.4274, -78.3351
Graphics of location attached
We have exhausted options to potential discharge locations closer to the facility. These options were eliminated due to
being classified as Swamp waters, having low flow characteristics, or by being in the Cape Fear River Basin (due to the
current development of a nutrient control strategy for the Middle Cape Fear). If modeling efforts are completed that
alleviate conditions that eliminated these options, we intend to revisit these options if time allows to develop another
Engineering Alternative Analysis.
I assume that due to the nature of social distancing and many people working remotely from their offices that this email
request will suffice. Please let me know if I should submit this request in another format.
Thank you.
Chris White, PE
Sr. Project IMIanager/ tngineer
[phone] x866 • Office
[phone] • Mobile
120 N. Boylan Ave.
Raleigh, NC 27603
ooten
2

APPENDIX E

PRELIMINARY ENGINEERING REPORT
IMPROVEMENTS TO THE
WASTEWATER TREATMENT FACILITY
TOWN OF BENSON, NORTH CAROLINA
FEBRUARY 23, 2007
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ARTHUR L. KENNEDY, PE, PLS
THE WOOTEN COMPANY
Engineering • Architecture • Planning
120 North Boylan Avenue
Raleigh, North Carolina 27603
[phone]
TWC Project No. 2293-AP

TABLE OF CONTENTS
1.0 SUMMARY, CONCLUSIONS AND RECOMMENDATIONS 1
2.0 INTRODUCTION 7
3.0 EXISTING AND FUTURE WASTEWATER FLOWS AND CAPACITY NEEDS 13
3.1 Population 13
3.2 Flow 15
3.2.1 Estimated Town Wastewater Flow (excluding I/I) 15
3.2.2 Estimated Town Infiltration and Inflow 17
3.2.3 Total Town Wastewater Flow 20
3.2.4 Johnston County Flow 20
3.2.5 Total Wastewater Flow and Capacity Reserve/Deficit 21
4.0 EXISTING WASTEWATER TREATMENT FACILITIES 23
4.1 Description 23
4.2 Performance Evaluation 25
4.3 Unit Operation and Process Performance 29
4.3.1 Mechanical Screen/Manually Cleaned By -Pass Screen 29
4.3.2 Grit Removal System 30
4.3.3 Influent Wastewater Pump Station 30
4.3.4 Modified BNR Activated Sludge System 31
4.3.5 Lime Feed System 33
4.3.6 Alum Feed System For Chemical Phosphorus Removal 33
4.3.7 Filter Lift Pumps 34
4.3.8 Tertiary Filtration System 34
4.3.9 Chlorination System 35
4.3.10 Dechlorination System 36
4.3.11 Aerated Sludge Stabilization/Storage Basin 37
4.3.12 Biosolids Disposal 38
5.0 INTERIM WASTEWATER TREATMENT FACILITIES 40
5.1 Description 40
5.1.1 Sewer Outfall Manholes and Diversion Box 40
5.1.2 Mechanical Screen/Manually Cleaned By -Pass Screen 40
5.1.3 Grit Removal System 42
5.1.4 Influent Wastewater Pump Station 42
5.1.5 Modified BNR Activated Sludge System 42
5.1.5.1 Oxidation Ditch Brushes 42

5.1.5.2 Lime Feed System 43
5.1.5.3 Alum Feed System For Chemical Phosphorus Removal 43
5.1.5.4 Splitter Box No. 1 43
5.1.5.5 Splitter Box No. 2 43
5.1.6 Secondary Clarifiers 43
5.1.7 Return Activated Sludge (RAS) 44
5.1.8 Filter Lift Station 44
5.1.9 Tertiary Filtration System 44
5.1.10 Chlorination System 44
5.1.11 Dechlorination System 44
5.1.12 Aerated Sludge Stabilization / Storage Basin 45
5.1.13 Biosolids Disposal 45
5.1.14 Yard Piping 45
5.1.15 Electrical 45
6.0 DESIGN BASIS 46
6.1 Influent Wastewater Flows and Characteristics 46
6.2 Effluent Limitations 47
7.0 ALTERNATIVES 52
7.1 Optimum Operation of the Existing Waste Treatment Facility 52
7.2 No Action Plan 53
7.3 Wastewater Reuse 53
7.4 Alternative Wastewater Treatment Systems 55
7.4.1 Alternative No. 1 — WWTP Expansion to 3.0 mgd, Expanded Discharge to Hannah Creek 56
7.4.1.1 Description 56
7.4.1.2 Estimated Project Cost 61
7.4.1.3 Estimated Annual Operation and Maintenance Costs 62
7.4.1.4 Estimated Salvage Value 63
7.4.1.5 Estimated Present Worth Cost 63
7.4.2 Alternative No. 2 — WWTP Expansion to 3.0 mgd, Expanded Discharge to the Neuse River 63
7.4.2.1 Estimated Project Cost 63
7.4.2.2 Estimated Annual Operation and Maintenance Costs 65
7.4.2.3 Estimated Salvage Value 66
7.4.2.4 Estimated Present Worth Cost 66
7.4.3 Alternative No. 3 — WWTP Expansion to 3.0 mgd, Expanded Discharge to Mingo Swamp 66
7.4.3.1 Estimated Project Cost 66
7.4.3.2 Estimated Annual Operation and Maintenance Costs 68
7.4.3.3 Estimated Salvage Value 69
ii

7.4.3.4 Estimated Present Worth Cost 69
7.4.4 Alternative No. 4 — WWTP Expansion to 3.0 mgd, Expanded Discharge Via Land Application69
7.4.4.1 Description 72
7.4.4.2 Estimated Project Cost 74
7.4.4.3 Estimated Annual Operation and Maintenance Costs 76
7.4.4.4 Estimated Salvage Value 77
7.4.4.5 Estimated Present Worth Cost 77
7.4.5 Alternative No. 5 — Maintain WWTP at 1.9 mgd, Pump Approx. 1.1 mgd Influent to Harnett
County System 77
7.4.5.1 Estimated Project Cost 78
7.4.5.2 Estimated Annual Operation and Maintenance Costs 79
7.4.5.3 Estimated Salvage Value 80
7.4.5.4 Estimated Present Worth Cost 80
7.4.6 Alternative No. 6 — Maintain WWTP at 1.9 mgd, Pump Approx. 1.1 mgd Influent to City of Dunn
System 80
7.4.6.1 Estimated Project Cost 81
7.4.6.2 Estimated Annual Operation and Maintenance Costs 82
7.4.6.3 Estimated Salvage Value 83
7.4.6.4 Estimated Present Worth Cost 83
7.5 Summary of Alternatives and Cost Analyses 84
8.0 PROPOSED IMPROVEMENTS 85
8.1 Description 85
8.2 Environmental Assessment 86
8.2.1 Existing Environment 86
8.2.2 Need for Project 86
8.2.3 Wastewater Treatment Alternatives Analysis 89
8.2.4 Existing Environmental Characteristics of Project Area 89
8.2.4.1 Topography 89
8.2.4.2 Geology and Soils 90
8.2.4.3 Land Use 90
8.2.4.4 Wetlands 91
8.2.4.5 Prime or Unique Agricultural Lands 92
8.2.4.6 Public Lands and Scenic, Recreational, and State Natural Areas 92
8.2.4.7 Areas of Archaeological or Historical Value 92
8.2.4.8 Air Quality 92
8.2.4.9 Noise Levels 92
8.2.4.10 Water Resources 93
iii

8.2.4.11 Forest Resources 93
8.2.4.12 Wildlife and Natural Vegetation 93
8.2.5 Environmental Consequences 94
8.2.5.1 Topography 95
8.2.5.2 Soils 95
8.2.5.3 Changes in Land Use 95
8.2.5.4 Wetlands 95
8.2.5.5 Prime or Unique Agricultural Lands 95
8.2.5.6 Public Lands 96
8.2.5.7 Scenic or Recreational Areas 96
8.2.5.8 Areas of Archaeological or Historical Value 96
8.2.5.9 Air Quality 96
8.2.5.10 Noise Levels 96
8.2.5.11 Water Resources 97
8.2.5.12 Forest Resources 97
8.2.5.13 Shellfish or Fish and their Habitats 98
8.2.5.14 Wildlife and their Habitats 98
8.2.5.15 Introduction of Toxic Substances 98
8.2.6 Mitigative Measures 99
8.2.6.1 Water Resources 99
8.2.6.2 Noise Levels 99
8.2.7 References 99
8.2.8 State and Federal Permits Required 99
8.3 Implementation 100
8.3.1 Institutional Responsibilities 100
8.4 Financing 100
8.4.1 Potential Sources 100
8.4.2 User Charges 102
iv

LIST OF TABLES
Table 1.1 — Summary of Alternatives 5
Table 2.1 — Summary of WWTP Upgrades: Interim Improvements (1.9 mgd) and Proposed Methods for
Handling Future Flows (3.0 mgd) 10
Table 3.1 — Historical Populations and Population Projections for Benson and Johnston County 13
Table 3.2 — Commercial and Institutional Unit Water Demands (1997) Along I-95 and I-40 16
Table 3.3 — Calculation of I/I in 2006 19
Table 3.4 — Breakdown of Flows to the Benson Wastewater Treatment Facility 22
Table 4.1 — Existing Chlorination System 35
Table 4.2 — Existing Dechlorination System 37
Table 6.1 — Proposed Design Influent Wastewater Characteristics 47
Table 7.1 — Estimate of Probable Cost for Alternative No. 1, WWTP Expansion to 3.0 mgd, Expanded
Discharge to Hannah Creek 61
Table 7.2 — Estimated Total Annual O&M Costs for Alternative No. 1, WWTP Expansion to 3.0 mgd,
Expanded Discharge to Hannah Creek 62
Table 7.3 — Estimate of Probable Cost for Alternative No. 2, WWTP Expansion to 3.0 mgd, Expanded
Discharge to the Neuse River 64
Table 7.4 — Estimated Total Annual O&M Costs for Alternative No. 2, WWTP Expansion to 3.0 mgd,
Expanded Discharge to the Neuse River 65
Table 7.5 — Estimate of Probable Cost for Alternative No. 3, WWTP Expansion to 3.0 mgd, Expanded
Discharge to Mingo Swamp 67
Table 7.6 — Estimated Total Annual O&M Costs for Alternative No. 3, WWTP Expansion to 3.0 mgd,
Expanded Discharge to Mingo Swamp 68
Table 7.7 — Estimate of Probable Project Cost for Alternative No. 4, WWTP Expansion to 3.0 mgd,
Expanded Discharge to Land Application 75
Table 7.8 — Estimated Total Annual O&M Costs for Alternative No. 4, WWTP Expansion to 3.0 mgd,
Expanded Discharge to Land Application 76
Table 7.9 — Estimate of Probable Cost for Alternative No. 5, Maintain WWTP at 1.9 mgd, Pump
Approx. 1.1 mgd Influent to Harnett County System 78
v

Table 7.10 — Estimated Total Annual O&M Costs for Alternative No. 5, Maintain WWTP at 1.9 mgd,
Pump Approx. 1.1 mgd Influent to Harnett County System 79
Table 7.11— Estimate of Probable Cost for Alternative No. 6, Maintain WWTP at 1.9 mgd, Pump
Approx. 1.1 mgd Influent to City of Dunn System 81
Table 7.12 — Estimated Total Annual O&M Costs for Alternative No. 6, Maintain WWTP at 1.9 mgd,
Pump Approx. 1.1 mgd Influent to City of Dunn System 82
Table 7.13 — Summary of Alternatives and Cost Analyses 84
Table 8.1 — Endangered, Threatened, and Rare Species in Johnston County 94
LIST OF FIGURES
Figure 2.1 — Location Map 8
Figure 3.1 — Historical Populations and Future Projections for Benson and Johnston County 14
Figure 3.2 — Projected Wastewater Capacity Need 21
Figure 4.1 — Existing Wastewater Treatment Plant Schematic — 1.5 mgd 24
Figure 5.1 — Interim Wastewater Treatment Plant Schematic — 1.9 mgd (Permitted Capacity) 41
Figure 6.1 — Map of Alternatives 51
Figure 7.1 — Proposed Wastewater Treatment Plant Schematic — 3.0 mgd (Expanded Discharge) 60
Figure 7.2 — Proposed Wastewater Treatment Plant Schematic — 3.0 mgd (Land Application) 70
Figure 7.3 — Proposed Land Application Site Plan Schematic 71
Figure 8.1 — Topographic Site Map Town of Benson WWTP 88
Figure 8.2 — Wetlands Online Mapper — Benson WWTP 91
vi

Appendix 2.
Appendix 3.
Appendix 3.
Appendix 4
Appendix 4
Appendix 4
APPENDICES
1 — NPDES Permit No. NC0020389 26 pages
1 — Draft PGI Pretreatment Permit 13 pages
2 — Four Oaks / Benson Interconnector and Town of Benson 0.4 mgd WWTP Expansion
Inter -Local Agreement 4 pages
.1 — Existing WWTP Design Data 5 pages
.2 — Sludge Management Plan and Residuals Land Application Permit 24 pages
.3 — Analysis of Residuals Land Application Permit vs. Lab Test Results from Annual
Monitoring Reports for 2002 and 2003 2 pages
Appendix 4.4 — Reclaimed Water Permit 10 pages
Appendix 4.5 — 2004 — 2006 Operating Data 5 pages
Appendix 6.1 — TWC Speculative Limits Request (6/25/01) 1 page
Appendix 6.2 — DWQ Response to Speculative Limits Request (1/23/06) 1 page
Appendix 7.1 — Preliminary WWTP Expansion Calculations 4 pages
Appendix 8.1 — FEMA Flood Maps 1 page
vii

1.0 SUMMARY, CONCLUSIONS AND RECOMMENDATIONS
The Town of Benson owns and operates a 1.5 million gallon per day (mgd) modified
biological nutrient removal advanced wastewater treatment plant (WWTP) that discharges its
treated effluent to Hannah Creek in the Neuse River basin. The plant is operated in accordance
with the requirements and conditions set forth in NPDES Permit No. NC0020389, which was
modified on January 20, 2006 and made effective on March 1, 2006.
The modified permit allows the plant's capacity to be increased to 1.9 mgd upon
construction of several plant improvements. These improvements, discussed in detail in Section
5.0, are being performed under a separate project.
The purpose of this report is to evaluate the treatment and discharge alternatives to
provide Benson with the ability of handling 3.0 mgd in future wastewater flows. As detailed in
this report, this would require either an expansion of the WWTP to 3.0 mgd capacity, or the
construction of pumping and force main facilities to divert approximately 1.1 mgd away from the
Benson plant.
As discussed in detail in Section 3.1 of this report, the population of Benson has
increased at an average rate of 24 persons per year between the years 1910 and 2000. This
population rate, however, is expected to increase as Research Triangle Park (RTP) and the
Raleigh area continue to grow. The addition of Interstate 40 has made commute time from
Benson to RTP much shorter. (See Figure 2.1.) As urbanization continues, favorable housing
prices, improved quality -of -life issues, and other parameters are likely to increase growth in
Benson.
With the growth in population comes an increase in wastewater flows. In fact, growth
has already caused a strain on water and sewer capacity in Johnston County and Clayton. If it
continues — and nothing indicates that it will slow down in the foreseeable future — both Johnston
County and Benson will have ever increasing water and sewer infrastructure needs.
1

To accommodate the increase in wastewater flows, Johnston County entered into an
agreement with Benson for additional capacity in the Benson WWTP. (See agreement in
Appendix 3.2.) Johnston County has requested a minimum of 0.15 mgd and up to a total of 0.50
mgd in capacity in Benson's WWTP. It has constructed a raw sewage force main from the Four
Oaks area to the Benson WWTP headworks.
It is recognized that the state requires that Benson plan for future expansion prior to the
plant's flow reaching 80 percent of the permitted flow. It is further recognized that the town
needs to provide adequate and reliable wastewater treatment and sludge handling facilities to
support the projected residential, institutional, commercial and industrial growth of Benson and
Johnston County. Therefore, it is necessary to upgrade and expand the town's ability to handle
3.0 mgd of wastewater by 2020. (See Figure 3.2.)
This study includes the following: an analysis of the historic and projected population
growth for the Town of Benson; an evaluation of the existing wastewater treatment system; a
description of the wastewater system after completion of the previously -proposed interim
improvements to bring permitted capacity to 1.9 mgd; a discussion of design wastewater flows,
characteristics and effluent limitations for discharge for expansion to 3.0 mgd; a detailed
discussion of the impairment of Hannah Creek, the town's actions upon learning of its inclusion
on North Carolina's 303(d) list, and its impact on future expansion at the Benson WWTP; an
analysis of six (6) potential alternatives for achieving expanded wastewater treatment and/or
transport; an environmental assessment; a discussion of financing; and a list of recommendations
for the town to pursue with regards to the impairment of Hannah Creek and the expansion of its
ability to handle future wastewater flows.
2

The conclusions drawn from this study are summarized as follows:
1. The on -going sewer system rehabilitation has reduced infiltration/inflow problems at the
plant.
2. The existing plant is operated well in terms of compliance with the permit limits on
BOD5, TSS, NH3-N, total nitrogen, and total phosphorus.
3. Existing influent wastewater characteristics are quite a bit weaker than typical domestic
municipal wastewater due both to low strength wastewater from Polymer Group,
Incorporated (PGI) and I/I.
4. The state's listing of Hannah Creek on the 303(d) List of Impaired Waters will at least
temporarily prevent the discharge of an additional 1.1 mgd to the stream.
5. Six (6) wastewater treatment and disposal or treatment and transport alternatives were
evaluated to provide the most cost-effective solution to the town's current and future
wastewater treatment needs. The total project cost, annual operation and maintenance
costs and present worth cost of the alternatives are evaluated in Table 1.1.
6. Should the treatment capacity of the WWTP be expanded to 3.0 mgd (under Alternatives
1,2,3or4):
a. The mechanical bar screen, grit chamber, comminutor, and Parshall flume will not
be adequate. They will be replaced with a new proposed headworks. The
proposed headworks will include a mechanical bar screen with a 7.5 mgd peak
capacity, screenings washing, compactor, bagging unit, and a manual bypass
screen. Also recommended is a vortex type grit removal unit with a 7.5 mgd peak
capacity, bypass channel, and dewatering screw classifier. The headworks
structure will also include a 12-inch Parshall flume for flow measurement.
b. New piping will be extended from the new headworks to the existing influent
distribution box so that excess flows during peak periods will pass through the
new mechanical bar screen and grit chamber before being transported to the
equalization basin.
c. The two (2) existing influent screw pumps are not of sufficient capacity for an
expansion to 3.0 mgd and would require replacement. The proposed influent lift
station will include space for three (3) submersible variable frequency drive
3

(VFD) pumps and will be equipped with two (2) such pumps at a peak capacity of
4.75 mgd (3,300 gpm) each.
d. A new anaerobic tank for phosphorus removal would be required for the
expansion.
e. Downstream of the new anaerobic tank, a new splitter box will divert flow to the
center anoxic ditch and the two (2) outer oxidation ditches.
f. In order to increase plant capacity without adding a new oxidation tank, it is
proposed to raise the walls of the existing oxidation ditches and anoxic ditch to
increase the volume of each ditch to 1.236 million gallons (MG).
g. It is proposed to construct an additional clarifier — Clarifier No. 6 — to handle the
increased flows.
h. It is recommended to convert the existing filter lift station, which is being
upgraded during the improvements to 1.9 mgd, to a RAS pumping station.
i. A new filter lift station is required at the addition flows to pump water to the filter
building and new denitrification filters.
j. The existing filters should be converted to denitrification filters. New
denitrification filters in parallel to the existing filters should be constructed to
handle increased flows.
k. A new ultraviolet (UV) disinfection facility to handle the peak flow of 7.5 mgd
would need to be constructed.
7. Should the permitted capacity of the WWTP be maintained at 1.9 mgd and approximately
1.1 mgd of influent diverted for treatment elsewhere (Alternatives 5 and 6):
a. A new influent pump station and force main would be required to transport raw
wastewater in excess of the 1.9 mgd average flow to Harnett County for treatment
and disposal
b. A new influent pump station and force main would be required to transport raw
wastewater in excess of the 1.9 mgd average flow to the City of Dunn for
treatment and disposal
4

Item
Alternatives
Alt. No. 1
Alt. No. 2
Alt. No. 3
Alt. No. 4
Alt. No. 5
Alt. No. 6
WWTP
Expansion
to 3.0 mgd,
Expanded
Discharge to
Hannah
Creek
WWTP
Expansion
to 3.0 mgd,
Expanded
Discharge to
Neuse River
WWTP
Expansion
to 3.0 mgd,
Expanded
Discharge to
Mingo
Swamp
WWTP
Expansion
to 3.0 mgd,
Expanded
Discharge to
Land
Application
Maintain
WWTP at
1.9 mgd,
Pump
Approx. 1.1
mgd
Influent to
Harnett
County
System
Maintain
WWTP at
1.9 mgd,
Pump
Approx. 1.1
mgd
Influent to
City of
Dunn
System
Total Project Cost
$16,345,000
$21,665,000
$18,953,000
$21,546,000
$10,040,000
$10,375,000
Annual O&M Cost
$790,000
$833,000
$825,000
$980,000
$758,000
$763,000
Present Worth
O&M Cost
$9,950,000
$10,492,000
$10,391,000
$12,343,000
$9,547,000
$9,610,000
Salvage Value
$4,190,000
$6,129,000
$5,141,000
$9,265,000
$3,410,000
$3,540,000
Present Worth Cost
$24,700,000
$29,800,000
$27,400,000
$30,300,000
$18,300,000
$18,600,000
Note: Costs are preliminary and in 2007 dollars. Do not use for construction.
Table 1.1— Summary of Alternatives
Based upon the findings of this study, the following recommendations are made to the
Town of Benson in order to address its future wastewater treatment needs.
1. The town should continue to work with the TMDL unit of DWQ to monitor dissolved
oxygen (DO) levels in Hannah Creek. If the data shows that DO levels increase so that
the values are computed to be above the impairment level, the town should work with the
TMDL unit to de -list Hannah Creek. (Note: In North Carolina, DO impairment in Class
`C' waters is triggered when >10.1% of the samples are less than 4 mg/L.) If Hannah
Creek were de -listed, the town would be able to pursue Alternative 1 as described in this
report.
2. The town should seek speculative limits from the state for discharge of the additional 1.1
mgd ADF to either the main stem of the Neuse River or to Mingo Swamp in the South
River Subbasin of the Cape Fear Basin. (It should be noted that according to
conversations with the state, it is unlikely that speculative limits for the discharge into the
5

Cape Fear Basin would be considered until that basin's model is fully operational.) If
speculative limits are granted for either the Neuse or Mingo Swamp, the town would be
able to pursue either Alternative 2 or Alternative 3 as outlined in this report.
3. The town should continue to be open to potential regional partners for the transport
and/or treatment of the town's wastewater. If a partner can be found and favorable
financing terms can be arranged, the town could pursue alternatives similar to Alternative
5 and Alternative 6 from this report.
4. The town should not consider selling any additional capacity at its WWTP until
provisions are made to either increase the permitted discharge capacity of the plant or
agreements are secured that would allow for the diversion of wastewater from the town to
another regional system for treatment.
5. The town should continue to explore water reuse in the region and be ever -aware of
potential industries or other entities that might serve as significant reuse consumers. As
indicated in the report below, the town currently has one small reuse project in operation
with the Johnston County Schools. Preliminary research done as part of this report did
not reveal any other imminent reuse customers in the immediate area.
6

2.0 INTRODUCTION
The Town of Benson is located in Johnston County at the interchange of Interstate 95 and
Interstate 40. (See Figure 2.1.) It owns and operates a 1.5 million gallon per day (mgd)
modified biological nutrient removal advanced wastewater treatment plant that discharges its
treated effluent to Hannah Creek in the Neuse River basin. The plant is operated in accordance
with the requirements and conditions set forth in NPDES Permit No. NC0020389. This permit
was recently modified, and the modified permit became effective on March 1, 2006. In
accordance with the modified permit, the Town of Benson is currently increasing plant capacity
to 1.9 mgd. A copy of the permit can be found in Appendix 2.1.
A review of the plant's monthly discharge monitoring reports (DMR's) for 2004 through
2006 reveals that the plant is performing as intended and is meeting permit requirements with
only occasional excursions. The plant's average daily flow was 1.135 mgd in 2004, 0.977 mgd
in 2005, and 1.191 mgd in 2006. The variation in annual averages can be explained by several
factors. The decrease in flow from 2004 to 2005 is at least partially the result of conservation
efforts by a large industrial user at the town, Polymer Group, Incorporated (PGI). More
significantly, the town began an aggressive and successful program to reduce UI into the system.
The reduced flows in 2005 are most assuredly a testament to the success of these efforts. The
increase in average flow from 2005 to 2006 can be explained by continued growth in the town's
service area, and also the contribution of 0.15 mgd from the Four Oaks area of Johnston County
via a completed force main. This force main began service on March 28, 2006.
The annual average flow in 2006 was 1.191 mgd. This is just below the NC Division of
Water Quality (NCDWQ) 80 percent capacity planning threshold (80% of 1.5 = 1.2 mgd). State
regulations require that prior to the annual average plant flow reaching 80 percent of the
permitted flow, the town must have in place a plan for expansion of its wastewater treatment
facilities.
7

To comply with the 80 percent capacity planning threshold, the Town of Benson
contracted with The Wooten Company to evaluate its wastewater needs. As part of its
preliminary evaluation, it was determined that the plant needed to be expanded to 3.0 mgd
capacity by 2020. As detailed in the PER for Interim Improvements to Wastewater Treatment
Facility, Town of Benson, North Carolina (published on March 29, 2005 and subsequently
amended on April 29, 2005, October 14, 2005, February 3, 2006, and March 1, 2006), the town
could not afford to perform this expansion in a single project. Though the population is expected
to grow, the cost of a single expansion would be too great for the current sewer customer base to
afford.
2ttliks•=l. Ile st.
Figure 2.1— Location Map
8

The expansion was thus divided into two distinct phases. The interim improvements
would increase the permitted plant capacity to 1.9 mgd. The ultimate expansion to 3.0 mgd
would then be planned so that it could be on-line by 2020. As much as possible, components
from the interim improvements would be incorporated in the expansion to 3.0 mgd.
However, in planning for the expansion to 3.0 mgd, it was learned that the state had listed
Hannah Creek as impaired for DO on its 303(d) List. This study thus had to consider two main
methods of handling the expected 3.0 mgd from Benson. First, it was thought the plant could
still be expanded to treat 3.0 mgd, assuming its effluent could be discharged in an approved
manner. This first line of thinking led to the development of this report's first four alternatives,
namely:
• Alt. No. 1 — WWTP Expansion to 3.0 mgd, Expanded Discharge to Hannah Creek
• Alt. No. 2 — WWTP Expansion to 3.0 mgd, Expanded Discharge to Neuse River
• Alt. No. 3 — WWTP Expansion to 3.0 mgd, Expanded Discharge to Mingo Swamp
• Alt. No. 4 — WWTP Expansion to 3.0 mgd, Expanded Discharge to Land
Application
Another line of thinking surmised that the plant's permitted capacity could be maintained
at 1.9 mgd and influent be diverted from the plant to another WWTP for treatment. This led to
the development of two additional alternatives:
• Alt. No. 5 — Maintain WWTP at 1.9 mgd, Pump Approx. 1.1 mgd Influent to
Harnett County System
• Alt. No. 6 — Maintain WWTP at 1.9 mgd, Pump Approx. 1.1 mgd Influent to City
of Dunn System
The previously -proposed interim improvements and the proposed methods for handling
the 3.0 mgd future flow are summarized in Table 2.1 below:
9

Treatment
Component
Proposed Previously
Proposed as Part of this Report
Interim Improvements to
WWTP
(1.9 mgd)
Ultimate Expansion of
WWTP(1.9
(3.0 mgd)
Alt. Nos. 1, 2, 3, & 4—
Maintain Current Capacity
mgd)
& Pump Additional
Influent (Approx. 1.1 mgd)
—Alt. Nos. 5 & 6—
Outfall
Manholes and
Diversion Box
• Raise select manholes
• Upgrade Diversion Box
_
Headworks
• Remove Comminutor
• Expand Grit Unit
• New Headworks Facilities
• New Headworks Facilities
Influent Lift
Station
• New Screw Pumps
• New Influent Lift Station
• New Influent Lift Station
and Pump Station
• Force Main
Modified BNR
Activated
Sludge System
• New Brush Motor Drives
and New Brushes
• New Splitter Box No. 1
• New Splitter Box No. 2
• New Flow Splitter Box
• Raise Walls of Ditches
• New Anaerobic Tank
■ Upgrade Internal Recycle
Capacity
Secondary
Clarifiers
• New Clarifier No. 5
• New Clarifier No. 6
Return
Activated
Sludge (RAS)
• New weir box
• New staff gate
• Convert Existing Filter Lift
Station to New RAS Pump
Station
Filter Lift
Station
• New Pump Impellers,
Motors, etc...
• New Filter Lift Station
Tertiary
Filtration
System
• Filter Evaluation
• Replace Media -
• New Filter Face Piping
• Convert Existing Filters to
Denitrification Filters
• New Parallel Train of
Denitrification Filters
Chlorination
System
• Raise weirs as necessary
• Upsize metering pumps as
needed
• New UV Disinfection
Facility
Water Reuse
• Reuse System (1.65 AC
on -site)
• Convert Existing Chlorine
System to Disinfection
System for Reuse
Biosolids
Disposal
• Maximize Permitted
Quantity
• Apply for Additional
Quantity
Yard Piping
• New Parallel Piping in
Some Sections from
Influent Lift Station to
Chlorine Contact Chamber
• Upgrade Some Piping As
Needed for Additional
Capacity
Secondary or
Advanced
(BNR) Effluent
Pumping
■ Required for Alt. Nos. 2, 3,
& 4
• Force Main for Alt. Nos. 2,
3, & 4
Electrical
• Additional Standby Power
Excluded
• Upgrade Electrical Service
• Upgrade Standby Power
• Upgrade Electrical Service
• Upgrade Standby Power
Site Work
• Misc. Site Work
• Misc. Site Work
• Misc. Site Work
Table 2.1— Summary of WWTP Upgrades: Interim Improvements (1.9 mgd) and Proposed
Methods for Handling Future Flows (3.0 mgd)
10

The need for the expansion of the town's wastewater treatment or capacity to transport
additional wastewater is due to the projected residential, commercial, and industrial growth in
the Benson area. Reviewing census data, Benson grew at an average rate of about 24 people per
year over the past ninety years ending in 2000. However, the rate of growth steadily decreased
during the last fifty years of this period. The average rates of growth were 18 and 10 people per
year during the past fifty and twenty year periods ending in 2000, respectively. The 2000 census
reported the population as 2,993. On the other hand, Johnston County has grown at an ever
increasing rate of growth over the same periods: 894, 1,120, and 2,565 people per year during
the past ninety, fifty, and twenty year periods ending in 2000, respectively. Much of Johnston
County's recent growth has come as a result of the Research Triangle Park (RTP) area.
The addition of Interstate 40 has made commute time from Benson to RTP much shorter.
As urbanization continues, housing prices, quality -of -life issues, and other parameters may
combine to cause an increase in growth in Benson. This may have already begun: over the three
year period from 2000 to 2003, the rate of growth was 80 and 4,801 people per year for the town
and county, respectively. Growth has already caused a strain on water and sewer capacity in
Johnston County and Clayton. If it continues, and nothing indicates that it will slow down in the
foreseeable future, both Johnston County and the Benson area will certainly continue to grow
and have ever increasing water and sewer infrastructure needs.
This residential growth will also stimulate institutional, commercial and industrial
growth. In fact, an industry in Johnston County has recently decided to expand its facilities, thus
creating new jobs. To handle this industry's sewer needs and in an effort to meet the needs of its
burgeoning population, Johnston County has requested capacity in the Benson wastewater
treatment plant. This will require provision of adequate, expanded wastewater treatment
facilities. Partial grant and loan funding have been acquired for this project.
It is recognized that the state requires that the town plan for future expansion prior to the
plant flow reaching 80 percent of the permitted flow. It is further recognized that the town needs
to provide adequate and reliable wastewater treatment and sludge handling facilities to support
11

the projected residential, institutional, commercial and industrial growth of itself and Johnston
County. Therefore, it is necessary to upgrade and expand the town's wastewater treatment plant
or construct means of diverting some of its future flows.
This study includes the following: an analysis of the historic and projected population
growth for the Town of Benson; an evaluation of the existing wastewater treatment system; a
description of the wastewater system after completion of the previously -proposed interim
improvements to bring permitted capacity to 1.9 mgd; a discussion of design wastewater flows,
characteristics and effluent limitations for discharge for expansion to 3.0 mgd; a detailed
discussion of the impairment of Hannah Creek, the town's actions upon learning of its inclusion
on North Carolina's 303(d) list, and its impact on future expansion at the Benson WWTP; an
analysis of six (6) potential alternatives for achieving expanded wastewater treatment and/or
transport; an environmental assessment; a discussion of financing; and a list of recommendations
for the town to pursue with regards to the impairment of Hannah Creek and the expansion of its
ability to handle future wastewater flows.
12

3.0 EXISTING AND FUTURE WASTEWATER FLOWS AND CAPACITY NEEDS
3.1 Population
Population data for Benson and Johnston County are tabulated in Table 3.1 and depicted
in Figure 3.1 below. As discussed in Section 2.0 above, Benson has grown at an average rate of
about 24 people per year over the past ninety years ending in 2000. However, the rate of growth
has steadily decreased during the last fifty years. The average rates of growth were 18 and 10
people per year during the past fifty and twenty year periods ending in 2000, respectively. The
2000 census reported the population as 2,993.
On the other hand, Johnston County has grown at an ever increasing rate of growth over
the same periods: 894, 1,120, and 2,565 people per year during the past ninety, fifty, and twenty
year periods ending in 2000, respectively. Much of Johnston County's recent growth has come
as a result of the continued suburbanization of the RTP and Raleigh areas.
Year
Benson
Johnston Co.
1910
800
41,401
1920
1,123
48,998
1930
1,522
57,621
1940
1,837
63,798
1950
2,102
65,906
1960
2,355
62,936
1970
2,267
61,737
1980
2,792
70,599
1990
3,044
81,306
1997
3,704
109,722
2000
2,993
121,900
2003
3,232
136,304
2005
3,300
145,240
2006
3,360
150,047
2010
3,600
169,273
2015
3,900
192,431
2020
4,200
218,509
2025
4,600
243,819
2030
5,040
272,060
Table 3.1 Historical Populations and Population Projections
for Benson and Johnston County
13

The addition of Interstate 40 has made commute time from Benson to RTP much shorter.
(See Figure 2.1.) As urbanization continues, more favorable housing prices, improved quality -
of -life issues, and other parameters may combine to cause an increase in growth in Benson. This
may have already begun. Over the three year period from 2000 to 2003, the rate of growth was
80 and 4,801 people per year for the town and county, respectively. For the town this is a growth
rate of 2.66 percent per year using 2000 as a base.
300,000
250,000
0
0
03 200,000
o
o,
0
a
, ▪ 150,000
0
0
U
c 100,000
I
b
': 50,000
0
t Johnston Co.
t Benson
1900 1920 1940 1960 1980 2000 2020 2040
Year
Figure 3.1— Historical Populations and Future Projections
for Benson and Johnston County
15,000
12,500
10,000td
151,
0
7,500 c
b
o
5,000 c
o
2,500
Projecting this rate of growth twenty years into the future may be too aggressive. It may
be more prudent to mirror the county's growth rate since it began to grow in 1970. During the
twenty year period from 1970 to 1990, Johnston County grew at a rate of 1.58 percent per year
using 1970 as a base. Therefore, a compound annual growth rate of 1.6 percent is used to project
Benson's population forward. Using the state demographer's 2003 population estimate of 3,232
14

for Benson as a base, the town's population is projected to increase to 3,300, 3,600, 3,900, 4,200,
4,600, and 5,040 in five year increments from 2005 to 2030, respectively. This is a total increase
over the twenty-five year period of about 56 percent.
Though its water system serves quite a few out-of-town customers, Benson, like many
other towns, has historically served sewer to in -town customers only. Therefore, the sewer
system population is the same as the town population. With the exception of the proposed bulk
service to Johnston County, it is assumed this trend will continue in the future.
3.2 Flow
3.2.1 Estimated Town Wastewater Flow (excluding I/I)
The town's 1992, 1997, and draft 2002 water supply plans provide snapshot details of its
water and sewer systems. A detailed review of the 1997 and 2002 plans reveals quite a few
potential errors. Therefore, estimation of wastewater flow from these plans must be tempered
with good engineering judgment and estimation.
From the 1997 plan, average daily water demand (ADD) was 1.473 mgd. Average daily
total wastewater flow (ADF) at the plant effluent (including I/I) was 1.307 mgd. The state
demographer's estimate of town population was 3,704. Wastewater flow excluding infiltration
and inflow (I/I) was estimated as follows:
Residential Flow = (3,704 people/2.4 people per house)(5,000 gallons per month per
house)(0.90 sewer/water) = 0.228 mgd
Commercial and Institutional Flow = (0.172 mgd + 0.021 mgd)(0.90 sewer/water) =
0.174 mgd
Industrial Flow = 0.552 mgd
Total Flow (excluding I/I) = 0.954 mgd.
Note that the commercial and institutional flow amounts to about 47 gallons per capita
per day (gpcd). This rate is higher than NCDWQ's typical rate of 15 gpcd. One possible reason
15

for the commercial and institutional unit flow being so much higher than DWQ's typical factor
may be that Benson is a popular waypoint for travelers along Interstates 95 and 40. It is
interesting to note that the local water supply plans' commercial and institutional unit water
demands for 1997 along Interstates 95 and 40 were as follows:
Town
Commercial and Institutional Unit Water Demands 1997
Lumberton
26 gpcd
Fayetteville
36 gpcd
Dunn
57 gpcd
Benson
64 gpcd (calculated using 2000 census)
Smithfield
43 gpcd
Rocky Mount
35 gpcd
Roanoke Rapids
23 gpcd
Table 3.2 — Commercial and Institutional Unit Water Demands (1997) Along I-95 and I-40
Also note that PGI contributed 0.530 mgd to the industrial flow. This amounts to over 55
percent of the total flow (excluding I/I). It currently has an industrial user pretreatment permit
with the town; this permit has recently been modified to permit a monthly average discharge of
0.400 mgd.
From the 2002 draft plan, average daily water demand (ADD) was 1.107 mgd. Average
daily total wastewater flow (ADF) at the plant effluent (including I/I) was 1.090 mgd. The state
demographer's estimate of town population was 3,057. Wastewater flow excluding infiltration
and inflow (I/I) was estimated as follows:
Total Flow (excluding I/I) = ((1.107 mgd ADD) — (0.172 mgd unaccounted-for) — (582
out-of-town residential customers)(5,000 gallons per month per customer))(0.90
sewer/water) = 0.755 mgd.
16

Total flow excluding I/I on a per capita basis was 258 and 247 gpcd for 1997 and 2002,
respectively. However, one cannot read too much into these two approximately equal unit
calculations for the following reasons:
• PGI wastewater makes up over 55 percent of the total flow in 1997. It has made
significant efforts over the past few years to conserve.
• The peak year for the recent, record -setting drought was 2002.
• The 1997 population estimate may have been in error, considering the 2000
census population.
Excluding PGI and I/I, the total per capita flows in 1997 and 2000 were 114 and 142 gpcd based
on 1997 estimated population and 2000 census population, respectively.
For future projections, the following is assumed:
• PGI flow will be at its new permitted monthly average limit of 0.400 mgd.
• Residential, commercial, and institutional flow will be proportional to town
population at the rate of 140 gpcd.
Using the population projections from Section 3.1 above, average wastewater flows (excluding
I/I) are projected to be 0.90, 0.95, 0.99, 1.04, and 1.11 mgd in five year increments from 2010 to
2030, respectively. Appendix 3.1 for the draft PGI pretreatment permit.
3.2.2 Estimated Town Infiltration and Inflow
Benson has approximately 246 inch -miles of collection and outfall piping. From
information provided in Section 3.2.1 above, I/I in 1997 was about 0.353 mgd on an annual
average basis. This was 27 percent of the total flow of 1.307 mgd. Winter (three wet months) I/I
was about 0.502 mgd. This was just over 2,000 gallons per day per inch -mile of pipe. This is
considered non -excessive by NCDWQ (excessive infiltration > 3,000 gpd/inch-mile).
In 2002 I/I was about 0.335 mgd on an annual average basis. This was 31 percent of the
total flow of 1.090 mgd. Winter (three wet months) I/I was approximately 0.518 mgd.
17

The National Oceanic and Atmospheric Administration (NOAA) provides weather data
for various sites across North Carolina. NOAA data for Dunn and Smithfield were averaged to
estimate rainfall for Benson. Normal annual precipitation for Benson is about 50 inches.
Approximately 44 inches of rain fell in 1997. The recent, record -breaking drought ended in late
2002. About 40 inches of rain was recorded that year.
It is interesting to note that even though the weather varied significantly between 1997
and 2002, the yearly average I/I and winter UI remained about the same. This is a testament to
the persistence of infiltration and the difficulty of effectively removing it. Inflow on the other
hand is much easier to identify and eliminate.
Inflow is difficult to quantify in Benson. Flow at the plant is measured at the effluent for
regulatory purposes. This captures all of the flow that is discharged to Hannah Creek. Flow is
also measured at the influent to the plant. Prior to the influent Parshall flume, inordinately high
peak flows are sent to two equalization basins. Flow to these basins is reported by the operator
to begin when the flow to the plant exceeds about 2.5 mgd. Only excess flow is diverted to the
basins. Effluent from these basins is pumped to the plant for treatment; however, the force main
discharges to the headworks downstream of the flume. Therefore, the influent flume does not
capture the true peak flow in the outfall nor does it capture the total flow coming into the plant.
The Wooten Company completed a Sanitary Sewer Evaluation Survey (SSES) for
Benson in 1998. This study identified about 0.345 and 0.0685 mgd in infiltration and inflow,
respectively. This agrees fairly well with the results calculated above. As a result of this study
the town began an extensive rehabilitation program. Approximately 21,000 linear feet (If) of
collection pipe and about 11,800 if of outfall sewer pipe were lined. This work was completed in
the fall of 2004.
Several significant sources of infiltration were identified and corrected. The
rehabilitation work on the collection system and outfalls also has been successful, particularly
with respect to inflow. For instance, the lag time between a rainfall event and an inflow peak
reaching the plant is reported by the operator to have increased from about 30 minutes to about
18

one hour. In addition the inflow peak is more gradual than before. With regards to infiltration,
flow at the plant decreased to about 1.14 mgd in 2004, 0.98 mgd in 2005, and 1.19 mgd in 2006.
At least part of this decrease was due to conservation efforts on the part of PGI. (Average
monthly flow from PGI during 2006 was 0.344 mgd.) However, it is believed that I/I abatement
efforts contributed significantly to this reduction.
If one looks in detail at the plant's flows from 2006, one can make some preliminary
conclusions regarding I/I. Johnston County began pumping from Four Oaks on March 28, 2006.
According to town staff, Johnston County flows are fairly consistent at 0.15 mgd. Flows from
PGI during this time are shown below. If one assumes a system population of 3,300 (see Table
3.1) at 140 gpcd, one can estimate I/I for this year. The data is summarized in Table 3.3.
Table 3.3 - Calculation of I/I in 2006
WWTP
Flow
(mgd)
Johnston
Co. Flow
(mgd)
PGI
Flow
(mgd)
Town Flows
(Excluding Ill)
(mgd)
Calculated
Ill (mgd)
Jan-06
1.219
1.048
0.966
1.035
1.293
1.257
1.198
1.112
1.113
1.014
1.594
1.448
0
0
0.015
0.15
0.15
0.15
0.15
0.332
0.47
0.42
Feb-06
0.340
0.47
0.24
Mar-06
0.322
0.47
0.17
Apr-06
0.340
0.47
0.08
May-06
0.340
0.47
0.33
Jun-06
0.351
0.47
0.29
Ju1-06
0.364
0.47
0.22
Aug-06
0.15
0.424
0.47
0.07
Sep-06
0.15
0.356
0.47
0.13
Oct-06
0.15
0.356
0.47
0.03
Nov-06
0.15
0.301
0.47
0.67
Dec-06
0.15
0.301
0.47
0.53
Average Ill (mgd)
0.27
AverageWinter I/I (mgd)
0.41
For future projections, it is assumed that I/I in 2006 averaged 0.27 mgd. Winter I/I is
assumed to be 0.41 mgd. It is further assumed that even as the collection system grows as the
population increases, infiltration and inflow will remain fairly constant as a result of the town's
ongoing rehabilitation program.
19

3.2.3 Total Town Wastewater Flow
Combining the projections from Sections 3.2.1 and 3.2.2 above, total wastewater flow
contributed by the town can be calculated. The annual average flow is projected to be 1.17, 1.22,
1.26, 1.31, and 1.38 mgd in five year increments from 2010 to 2030. Likewise, the winter (wet
weather months) average flow is projected to be 1.31, 1.36, 1.40, 1.45, and 1.52 mgd.
Note that the 2004 annual average flow was 1.135 mgd. This was reduced to 0.977 mgd
in 2005. The major difference between these flows can be explained by PGI and the successful
work during I/I rehab. The increase in flows from 2005 to 2006 — from 0.977 mgd to 1.191 mgd,
respectively — is most likely the result of the town's increased growth and the 0.15 mgd
contribution from the Four Oaks / Johnston County force main.
3.2.4 Johnston County Flow
As previously discussed, growth has already caused a strain on water and sewer capacity
in Johnston County and Clayton. An industry in Johnston County recently decided to expand its
facilities, thus creating new jobs. To handle this industry's sewer needs and in an effort to meet
the needs of its burgeoning population, Johnston County purchased capacity in the Benson
wastewater treatment plant (reference the agreement in Appendix 3.2). Johnston County
purchased 0.15 mgd and had intended to procure an additional 0.35 mgd in capacity in Benson's
wastewater treatment plant (WWTP). This additional purchase of capacity — to bring total
Johnston County flow to 0.50 mgd, is on hold due to the impairment of Hannah Creek and its
impact on Benson WWTP discharge limits. (See discussion on effluent limits in Section 6.2.)
In the meantime, Johnston County has constructed a raw sewage force main from the
Four Oaks area to the Benson wastewater treatment plant headworks. Discharge to Benson's
WWTP was initiated on March 28, 2006.
20

3.2.5 Total Wastewater Flow and Capacity Reserve/Deficit
The results calculated and projected in Sections 3.2.1 through 3.2.4 above are
summarized graphically in Figure 3.2 below. These projections assume that PGI, or a
combination of PGI and new industry, will make use of the 0.400 mgd monthly average
permitted capacity now held by PGI.
3.500
3.000 -
2.500
�o^n 2.000
E
w 1.500
1.000
0.500
0.000
3.0 mgd on-line 2020
1.9 mgd on-line 2008
2000 2005 2010 2015 2020 2025 2030
Year
2035
Winter flow w/ 0.5mgd
from Johnston Co.
Avg flow w /0.5 mgd from
Johnston Co.
� — Winter flow w/ 0.15mgd
from Johnston Co.
— o Flow w/winter I/I
—X—Avg flow w/ 0.15 mgd from
Johnston Co.
--*-- Flow with avg I/I
• - Flow Excluding I/I (PGI @
permit flow of 0.400 mgd)
- • Flow Excluding I/I & PGI
Plant Capacity
- - - 80% of Plant Capacity
Note: Current PGI Flow is approximately 0.34 mgd
Figure 3.2 Projected Wastewater Capacity Need
The current monthly average plant capacity is 1.5 mgd. This is currently being expanded
to a permitted capacity of 1.9 mgd on an interim basis to provide Johnston County with 0.15 mgd
monthly average permitted capacity.
According to projected flows, the plant could remain at 1.9 mgd permit capacity until
2020, when its average flow would reach 80% of this flow. It is proposed to permanently
increase the plant capacity to 3.0 mgd by 2020. This expansion, using currently available
21

technology, would maximize both the existing infrastructure and existing land at the current
plant site and is the most logical and economical incremental size increase. As Figure 3.2
indicates, this 3.0 mgd facility would provide the town with reserve capacity well beyond 2030.
Table 3.4 below shows the breakdown of the contributing wastewater sources and their
calculated flows for the years 2010, 2015, 2020, 2025, and 2030.
Table 3.4 - Breakdown of Flows to the Benson Wastewater Treatment Facility
Year
2010
2015
2020
2025
2030
Residential
0.274
0.296
0.319
0.350
0.402
Commercial/Institutional
0.209
0.226
0.244
0.267
0.303
Industrial: PGI
0.400
0.400
0.400
0.400
0.400
:Other
0.022
0.023
0.025
0.028
0.031
: Future Ind. Allocation
0.091
0.095
0.099
0.105
0.114
Average I&I
0.270
0.270
0.270
0.270
0.270
Average Flow
1.266
1.310
1.357
1.420
1.520
Winter I&I (Nov - Mar)
0.41
0.41
0.41
0.41
0.41
Winter Flow (Nov - Mar)
1.406
1.450
1.497
1.560
1.660
Johnston County
0.15
0.15
0.15
0.15
0.15
Average Flow
1.416
1.460
1.507
1.570
1.670
Winter Flow (Nov - Mar)
1.556
1.600
1.647
1.710
1.810
Johnston County
0.5
0.5
0.5
0.5
0.5
Average Flow
1.766
1.810
1.857
1.920
2.020
Winter Flow (Nov - Mar)
1.906
1.950
1.997
2.060
2.160
22

4.0 EXISTING WASTEWATER TREATMENT FACILITIES
4.1 Description
The Town of Benson operates a 1.5 mgd modified biological nutrient removal advanced
wastewater treatment plant. Construction will be initiated in the spring of 2007 to expand the
plant to a permitted capacity of 1.9 mgd. Its treated effluent is discharged to Hannah Creek, a
tributary to the Neuse River. The plant consists of a mechanically cleaned bar screen, a manually
cleaned bar screen (by-pass), a mechanically cleaned grit removal system, a comminutor, 9-inch
Parshall flume for influent flow metering, influent wastewater pumping, modified oxidation
ditches for biological nutrient removal, secondary clarifiers, sludge recirculation and waste
pumping, nitrate internal recycle pumps, lime feed system for alkalinity and pH control, alum
feed system for back-up chemical phosphorus removal and effluent polishing, tertiary filtration,
chlorine disinfection system, dechlorination system, post aeration, aerated sludge holding basin
for long-term sludge stabilization and storage, and sludge loading station for disposal of
stabilized sludge by land application. A schematic flow diagram is shown on Figure 4.1 below.
Detailed design data for the existing Benson WWTP is given in Appendix 4.1. Refer to
Appendix 2.1 for a copy of the current NPDES permit. Refer to Appendix 4.2 for a copy of the
town's sludge management plan. Also included in this appendix is a copy of Benson's residuals
land application permit (WQ0012514) dated September 27, 2002, and amended February 27,
2004. Residuals are land applied in Sampson County.
Benson is currently operating a reclaimed water system. See Appendix 4.4 for a copy of
the permit (WQ0022501) dated June 10, 2004. The permit allows for a yearly maximum
application rate of 23,240 gallons per day (gpd) onto 7.1 acres. However, at the present time a
1.9 acre soccer field is currently not being irrigated. Application is thus currently limited to 5.2
acres, or a maximum of 17,020 gpd on an annual basis.
23

dct/ f
•
•
FEBRUARY 2007
TOWN OF BENSON
NORTH CAROLINA
VWVTP EXPANSION
ALTERNATIVES
TT
THE WOOTEN COMPANY
ENGINEERING PLANNING ARCHITECTURE
120 North Boylan Avenue Raleigh NC 27603-1423
919.828.0531 fax [phone]
•
FIGURE 4.1
iL
x
SLUDGE AERA11ON BASIN
EXI-IEMATIC - 1.5 MGD

4.2 Performance Evaluation
Operating data, as recorded on the monthly monitoring reports for 2004 through 2006,
was reviewed to evaluate plant influent wastewater characteristics and performance. Reference
is made to Appendix 4.5.
For regulatory purposes as previously discussed, flow is measured at the effluent (just
following post aeration). In 2004, the annual average flow was 1.135 mgd. This decreased in
2005 to 0.977 mgd, and then increased to 1.191 mgd in 2006. For 2004, daily average flow
varied from a low of 0.505 to a high of 2.848 mgd. In 2005, this range was 0.401 to 3.009 mgd.
In 2006, flows ranged from a low of 0.581 to 2.965 mgd. The peak daily average flow to annual
average flow ratio was 2.5. The plant is currently designed, built, and permitted for a maximum
monthly flow of 1.5 mgd. This flow limit was exceeded twice during the study period: 1.688
mgd in September 2004 and 1.594 mgd in November 2006..
The plant's NPDES permit was revised in January 2006 and made effective on March 1,
2006. The revised permit allows a monthly average flow of 1.9 mgd. This increase is contingent
upon the completion of the interim improvements of the WWTP discussed in Section 5.0.
The 2006 annual average flow of 1.191 mgd is about 79 percent of the permitted capacity
of 1.5 mgd. This is just below the NCDWQ 80 percent capacity planning threshold (80% of 1.5
= 1.2 mgd). State regulations require that prior to the annual average plant flow reaching 80
percent of the permitted flow the town must have in place a plan for expansion of its wastewater
treatment facilities. This PER, as well as the PER for Interim Improvements to Wastewater
Treatment Facility, Town of Benson, North Carolina, published on March 29, 2005 and
subsequently amended on April 29, 2005, October 14, 2005, February 3, 2006, and March 1,
2006, comprises the study of WWTP expansion in compliance with the planning threshold
regulation.
Average monthly influent five day biochemical oxygen demand (BOD5) concentrations
in 2004 ranged from 56 milligrams per liter (mg/1) to 161 mg/1 and averaged 85 mg/1. In 2005,
25

the average monthly influent BOD5 ranged from 70 mg/L to 186 mg/L and averaged 101 mg/L.
In 2006, the average monthly influent BOD5 ranged from 63 mg/L to 149 mg/L and averaged
110 mg/L. The increase in influent BOD5 concentration is most likely due to successful efforts
to eliminate I/I and to water conservation efforts and low -flow plumbing fixtures.
In 2004, average monthly organic loading ranged from 570 to 1,200 pounds of BOD5 per
day (lb BOD5/day) and averaged 800 lb BOD5/day. In 2005, the range was 550 to 1,300 lb
BOD5/day with an average of 800 lb BOD5/day. In 2006, average monthly organic loading
ranged from 630 to 1, 500 lb BOD5/day and averaged 1,100 lb BOD5/day.
Analysis of the three years of DMR data reveals that a peak organic loading factor of 1.5
(as compared to annual average loading) is appropriate. For the most recent year of 2006, this
calculates to a peak BOD5 loading of 1,650 pounds per day (ppd). Design influent BOD5
concentration and organic loading are 200 mg/1 and 2,500 ppd, respectively. This indicates that
the plant is well within its design influent BOD5 concentration and organic loading.
In 2004, average monthly effluent BOD5 concentrations ranged from 0.1 mg/1 (a summer
month) to 4.9 mg/1 (a winter month) and averaged 2.2 mg/1. In 2005, effluent BOD5
concentrations ranged from 2.5 mg/L (a summer month) to 7.6 mg/L (a winter month) and
averaged 4.4 mg/L. In 2006, the effluent BOD5 range was 0.3 mg/L (two summer months) to 4.5
mg/L (a winter month) and averaged 2.2 mg/L. Benson's discharge limitation for BOD5 is 5.0
mg/1 in the summer and 10.0 mg/1 in the summer. Therefore, the plant has no problems
complying with BOD5 effluent limits. Average monthly BOD5 removals for 2004, 2005, and
2006 were 97.4%, 95.4%, and 98.1%, respectively. The NPDES permit requires 85 percent
BOD5 removal. This again shows that the plant has no organic loading problems. However, the
daily maximum BOD5 was above the new reclaimed water permit limit of 15 mg/1 on at least one
day in each of two months. The new reclaimed water system thus requires careful operator
attention.
Average monthly influent total suspended solids (TSS) concentrations in 2004 ranged
from 94 mg/1 to 313 mg/1 (due to septage) and averaged 142 mg/1. In 2005, influent TSS ranged
26

from 111 mg/L to 173 mg/L and averaged 133 mg/L. In 2006, influent TSS ranged from 134
mg/L to 159 mg/L and averaged 143 mg/L. Design influent TSS concentration is 200 mg/1.
Average monthly effluent TSS concentrations for 2004 ranged from 6 mg/1 to 10 mg/1 and
averaged 8 mg/1. In 2005, the effluent TSS ranged from 5 mg/L to 11 mg/L and averaged 7
mg/L. In 2006, effluent TSS ranged from 4 mg/L to 8 mg/L and averaged 5 mg/L. The averaged
TSS removal for 2004, 2005 and 2006 was 94.0%, 94.9%, and 96.2%. The discharge limitation
on TSS, as given in the NPDES permit, is 30 mg/1 and 85% removal. Both conditions were
easily met, demonstrating compliance with permit conditions. However, both monthly average
and maximum daily TSS concentrations exceeded the new reclaimed water permit limits of 5 and
10 mg/1, respectively.
As noted in the 1.9 mgd PER, the existing filters should be able to meet these new TSS
limits. Before any definite conclusions can be drawn as to why this problem exists, the
following items need to be investigated:
• Evaluate food to mass ratio and sludge age currently being used at the plant.
• Evaluate TSS concentration in the filter influent.
• Evaluate the condition of the filter media and filters. It is believed that the media
may not have been replaced since the filters were built.
Possible solutions to this problem include:
• Modify the biological process to improve filtration characteristics.
• Feed polymer or alum to the filter influent.
• Replace the filter media.
The biological process may be modified at no capital cost and minimal operating cost. Alum and
polymer feed facilities are already in place at the plant. One of these coagulants can be used
effectively to improve operation until the filter media can be replaced.
27

In 2004, average monthly effluent NH3-N concentrations ranged from 0.2 mg/1 (a
summer month) to 1.2 mg/1 (a summer month) and averaged 0.4 mg/l. In 2005, average monthly
effluent NH3-N ranged from 0.2 mg/L (a winter month) to 0.8 mg/L (a summer month) and
averaged 0.4 mg/L. In 2006, effluent NH3-N ranged from 0.1 mg/L (a summer month) to 0.4
mg/L (a winter month) and averaged 0.2 mg/L. Benson's discharge limitation for NH3-N is 4.0
mg/1 in the winter and 2.0 mg/1 in the summer for 1.5 mgd. Therefore, the plant has had no
problems complying with NH3-N effluent limits.
Average monthly effluent total nitrogen concentrations in 2004 ranged from 2.8 mg/1 to
6.8 mg/1 and averaged 4.4 mg/1; in 2005 the range was 3.3 mg/L to 6.6 mg/L and the average was
4.8 mg/1; in 2006 the range was 1.6 mg/L to 7.8 mg/L with an average of 3.8 mg/L. In 2004, the
annual total nitrogen discharge loading was 14,565 pounds per year (ppy). In 2005, it was 14,325
ppy, and in 2006 it was 13,212 ppy. The discharge limitation on total nitrogen, as given in the
NPDES permit, is 33,790 ppy for both 135 mgd and 1.9 mgd. Thus the plant has operated well
within its discharge limits on annual mass loading of total nitrogen.
No monitoring data for influent total phosphorus concentration is available. However,
the total phosphorus concentration of a typical domestic wastewater is in the range of 4 to 8 mg/1.
Note that the influent wastewater in Benson appears to be about half the concentration typically
expected, based on BOD5. The plant is designed for chemical phosphorus removal using an
influent total phosphorus concentration of 8 mg/1. Average monthly effluent total phosphorus in
2004 ranged from 0.5 mg/1 to 1.1 mg/1 and averaged 0.9 mg/1. In 2005, the range was 0.8 mg/L
to 1.9 mg/L and the average was 1.3 mg/L. For 2006, the range in effluent total phosphorus was
0.7 mg/L to 1.8 mg/L and the average was 1.4 mg/L. Benson's discharge limitation for total
phosphorus is 2.0 mg/1 on a quarterly average basis for both 1.5 mgd and 1.9 mgd. The reported
effluent total phosphorus concentrations are without any chemical use for phosphorus removal.
The operational practices of the oxidation ditch system achieve biological phosphorus removal,
and the plant has no problems in compliance with the effluent total phosphorus limit.
28

Dissolved oxygen averaged 8.3 mg/1 in 2004, 8.2 mg/L in 2005, and 8.9 mg/L in 2006.
There was an excursion below the NPDES permit daily minimum of 6.0 mg/1 during one month
in 2004.
The maximum monthly average for fecal coliform was 8 per 100 milliliters (8/100 ml) in
2004, 39/100 ml in 2005, and 10/100 ml in 2006. These were well below the NPDES permit
limit of 200/100 ml. However, the daily maximum fecal coliform count was above the reclaimed
water permit limit of 25/100 ml on at least one day in each of nine months. Therefore, it is
required to increase chlorine feed concentrations for the reclaimed water system.
The NPDES permit daily limit of 17 micrograms per liter (ug/1) went into effect May 1,
2005. This limit was exceeded once during the study period in August 2006
Finally, the NPDES permit daily limit of 0.012 ug/1 for mercury was exceeded in two
months during 2004, in three months during 2005, and in one month in 2006.
4.3 Unit Operation and Process Performance
Performance of the major unit operations/processes at the Benson wastewater treatment
plant is discussed below. Probable causes of unit operation/process problems, including
mechanical condition of the associated equipment, are also discussed.
4.3.1 Mechanical Screen/Manually Cleaned By -Pass Screen
One manually cleaned bar screen and one automatically self-cleaning arc bar screen are
provided at the plant. The manual screen is located in the diversion structure that typically sends
excess flow to the equalization basins. The by-pass manual screen and the mechanical screen are
each designed to handle peak hydraulic flows of 1.65 and 3.75 mgd, respectively. The self-
cleaning bar screen is manufactured by Enviroquip, Inc. and consists of a carbon steel screen in
the shape of an arc, a mounting frame, a pivoting rake wiper, a pivoting discharge apron, a drive
unit mounted on an adjustable plate and a control panel with magnetic motor starter. The
29

mechanical screen has 0.5 inch screen openings. Since the screen is not equipped with screenings
washing facilities, it removes a significant quantity of organics with the screenings. The
screenings with high content of putrescible organic matter do, at times, create nuisance
conditions. During high wind conditions the screenings on the raking arm are sometimes
dislodged and fall to the ground near the screen structure. NCDWQ has raised some concerns
about the screenings on the ground. As a part of its normal operation and maintenance (O&M)
practice, the plant staff routinely inspects and cleans the screening facilities and the ground area
around the screening facilities.
4.3.2 Grit Removal System
The grit removal system at the plant consists of a rectangular grit collection tank. It is
equipped with a chain and scraper type grit collecting mechanism manufactured by Envirex, Inc.
A design check of this unit reveals that it can continue to operate effectively up to a peak flow of
1.7 to 2.1 mgd. The grit collection system was installed during the 1978 plant upgrade and is in
a deteriorating condition due to age.
4.3.3 Influent Wastewater Pump Station
The influent wastewater pump station includes three screw pumps, lead -lag operation
selector switch and a control panel. Pumps No. 1 and No. 2 were installed in 1977 and are rated
for 1,370 gallons per minute (gpm) at 7 ft. of lift head each. Pump No. 3 was installed in 1988
and is rated for 1,750 gpm at 7 ft. of lift head. The pumps are operated in duplex mode, keeping
one pump to serve as a standby unit. Evaluation of the mechanical conditions of the pumps
indicated that the lower bushing and bearing of Pump No. 1 need replacement. Also, the same
pump scrubs the concrete when it is put into operation.
30

4.3.4 Modified BNR Activated Sludge System
Originally the Town of Benson operated an oxidation ditch type extended aeration
activated sludge system. The system originally consisted of two oxidation ditches, but was
updated to three oxidation ditches in parallel (0.567 million gallon (MG) capacity each with four
7.5 horsepower (hp) brush rotors per ditch), four secondary clarifiers (two at 35 feet diameter x
10 feet side water depth (SWD) each and two at 35 feet diameter x 12 feet SWD each), two
sludge recirculation pumps (1,050 gpm at 17 feet total dynamic head (TDH) each), one waste
sludge pump (100 gpm at 10 feet TDH), and two scum pumps (100 gpm at 10 feet TDH each).
In 2000 the oxidation ditch system was modified to achieve biological nutrient removal at
the plant. The modifications included installation of 4 hp mixers in the ditches: four in the
middle ditch, and two in each of the outer ditches. An internal mixed liquor recycle system was
installed to transfer liquor from the middle tank to the two outer tanks and back. It consisted of
two 2,800 gpm submersible propeller pumps to pump nitrate laden mixed liquor from the outer
ditches to the middle ditch for denitrification and two 24-inch connecting pipes to send organic
laden waste to the outer ditches for BOD5 removal and nitrification. A dissolved oxygen
monitoring system was placed into each ditch. Under normal conditions, raw sewage and return
sludge first enter the middle ditch. This ditch is kept anoxic. Flow then proceeds to the two
outer ditches. These ditches are operated aerobically. Internal recycle between the anoxic and
aerobic tanks provides for nitrification and denitrification and BOD5 removal.
The three oxidation ditches at the plant are designed to provide 27 hours hydraulic
retention time at an average daily flow of 1.5 mgd. The original design organic loading, F/M
(food to microorganism) ratio, and MCRT (mean cell residence time) are 11 lb BOD5 per 1,000
cubic feet per day, 0.08 lb BOD5 per lb MLV S S (mixed liquor volatile suspended solids) per
day, and 24 days, respectively, based on standard parallel operation (not BNR mode). The plant
is currently organically underloaded. Using 2004 yearly average data (reference Appendix 4.5)
and normal BNR mode (consideration of two aerobic basins only), the hydraulic retention time is
31

24 hours, and the organic loading is 5.3 lb BOD5 per 1,000 cubic feet per day. Under such
underloaded operating conditions, the oxidation ditch system provides wastewater treatment as
well as sludge stabilization. The plant is operated well in terms of compliance with the permit
limits on BOD5, TSS, NI-13-N, total nitrogen, and total phosphorus. Operating in BNR mode has
so far eliminated the need for supplemental lime for nitrification and alum feed for chemical
phosphorus removal.
Structurally, the oxidation ditches are in excellent condition. Mechanically, the brush
rotor aerators are in good condition.
The four clarifiers are designed to provide 390 gpd per square foot (gpd/sf) surface
overflow rate, five hours hydraulic retention time, and 3,410 gpd per linear foot (gpd/lf) weir
overflow rate at an average daily flow of 1.5 mgd. Under design conditions and using a 100
percent return sludge ratio, the average solids loading rate on the clarifiers is 0.85 pounds MLSS
(mixed liquor suspended solids) per hour per square foot. Therefore, the clarifiers are
conservatively designed. Mechanically, the clarifiers are in good condition. The town provides
routine preventive maintenance as recommended by the manufacturer.
Two sludge recirculation pumps provide the sludge recirculation need of the modified
BNR oxidation ditch system. Each pump is designed to provide a sludge recirculation flow of 1.5
mgd, which is 100 percent of the design average daily flow (1.5 mgd). Under the present BNR
operation mode the sludge is recycled to the middle oxidation ditch for its operation as
anaerobic/anoxic ditch for enhanced biological phosphorus removal and denitrification.
Mechanically, both the sludge recirculation pumps are in good condition, and the town performs
routine preventive maintenance as recommended by the pump manufacturer.
One waste sludge pump is provided for sludge wasting needs from the modified BNR
oxidation ditch system. No standby waste sludge pump is provided because the piping
arrangement with the scum pump also allows use of the scum pumps for sludge wasting.
Mechanically, the waste sludge pump is in good condition, and the town performs routine
preventive maintenance as recommended by the manufacturer.
32

Two scum pumps are provided to pump the skimmings waste of the clarifiers to the long-
term aerated sludge stabilization/holding tank. The pumps are operated in duplex mode and
alternated to assume the lead role after each pumping cycle. Mechanically, the scum pumps are
in good condition, and the town provides routine preventive maintenance as required by the
manufacturer.
4.3.5 Lime Feed System
The lime storage and feed system at the plant is a factory built unit which provides
automatic mixing and feeding of hydrated lime to the influent of the oxidation ditches. The
system is designed to add necessary alkalinity for the nitrification process in the oxidation ditch
system. The system is designed to produce a lime slurry of specific or desired lime
concentration. The slurry is then fed in proportion to a signal generated by the influent flow
meter at the Parshall flume. The lime storage bin has a capacity to store 1,800 cubic feet (CF) of
hydrated lime. The feed pump capacity is 0.5 gallons of lime slurry per hour against a discharge
head of 25 feet. After the installation of the nutrient removal facilities in the oxidation ditches,
sufficient alkalinity is recovered back during the denitrification process. Therefore, at the
present time the lime feed system is not being used. The town is keeping the system for
operational readiness should lime feed be needed to optimize nitrification in the oxidation ditch
system.
4.3.6 Alum Feed System For Chemical Phosphorus Removal
The alum feed system at the plant includes two 15,000 gallon bulk storage tanks, two 50
gallon per hour feed pumps, and necessary piping and controls. The system is designed to
remove 2 to 6 mg/1 total phosphorus by feeding alum into the oxidation ditch mixed liquor
effluent prior to settling in the secondary clarifiers. In the past the plant has used the alum feed
system on an occasional basis for compliance with the effluent limit on total phosphorus. Most
33

of the time compliance was achieved through biological phosphorus removal by simply
manipulating aerator operation in the oxidation ditches. After the installation of the nutrient
removal facilities, the plant has consistently complied with the effluent limit on total phosphorus
biologically. At present, no alum is being fed for phosphorus removal; however, the alum feed
system is kept in a state of readiness if alum feed is warranted for phosphorus removal due to
biological upset in the modified oxidation ditch system. As previously discussed, alum may be
needed on a temporary basis to achieve reclaimed water quality. Mechanically, the alum feed
system is in excellent condition.
4.3.7 Filter Lift Pumps
Three filter lift pumps (1,300 gpm at 34 feet TDH each) are provided for pumping the
secondary clarifier effluent to the tertiary filters. The pumps are operated in duplex mode,
keeping one pump to serve as a standby unit. Mechanically, the pumps are in good condition and
controls are functioning properly.
4.3.8 Tertiary Filtration System
The tertiary filtration system at the plant consists of five gravity, dual media filters, 10
feet x 12 feet each. Media consists of 27 inches of anthracite over 12 inches of sand. The
underdrain system is a Wheeler bottom type with gravel. The filters are each equipped with sub-
surface rotary sweeps. A polymer filter aid system is provided for use when needed.
The design filtration rates at average daily and peak daily flows are 1.74 gpm per square
foot (gpm/sf) and 4.34 gpm/sf, respectively. The filter backwash rate is 15 gpm/sf. From
conversations with plant staff, each filter is currently backwashed about twice per week. The
filters can be backwashed in manual as well as in automatic mode. However, the automatic
backwash system is not functional at the present time and is in need of repair or replacement.
The rotary sweeps are also non-functional and in need of repair or replacement. As previously
34

discussed, the filters are performing well in regards to the NPDES permit requirements but
cannot meet the new reclaimed water requirements. This may be due to the need for media
replacement and/or rehabilitation. As a temporary solution alum or polymer may be used on top
of the filters or clarifiers to improve performance. It is also understood that after completion of
the interim improvements project — which includes repair of filter cell no. 5 — the town will use a
dedicated portion of its operation and maintenance fund to replace the media in all filter cells.
4.3.9 Chlorination System
Disinfection of the tertiary filter effluent is accomplished by chlorination. The design
description of the chlorination system is given as follows:
Item
Info.
Number of parallel, baffled tanks at 23'-6" x 8'-8" x 6'-6" SWD each
2
Unit volume, gallons
9,900
Total volume, gallons
19,800
Theoretical hydraulic detention time at average daily flow (minutes)
19
Number of chlorinators
2
Chlorine feed rate, ppd (original design)
20 - 200
Number of one -ton cylinders (original design)
4
Table 4.1— Existing Chlorination System
As shown, the average theoretical chlorine contact time is 19 minutes. This is less than
the standard design practice of 30 minutes. However, additional chlorine contact time is
provided by the filter backwash storage tank located just downstream of the chlorine contact
tank. This tank is not baffled. Considering the 20,475 gallon available volume of the filter
backwash tank, the combined theoretical chlorine contact hydraulic retention time is 38.7
minutes.
35

Review of the fecal coliform data for 2004 through 2006 shows that the chlorination
system is providing superb disinfection with respect to the town's NPDES permit requirements.
However, Benson is currently operating a reclaimed water system. As previously discussed,
chlorine dose has been increased to reliably meet the more stringent requirements of the town's
reclaimed water permit.
A few years ago, considering low chlorine demand requirements and the need for better
control of chlorine feed during low flow conditions, the town replaced the existing chlorinators
with 0-50 ppd chlorinators. Existing chlorine feed at the plant is reportedly in the range of 20 to
40 ppd. The town also replaced the chlorine gas alarm system a few years ago.
NCDWQ requires Benson to measure flow at the effluent for compliance purposes. The
reasons for this were discussed in detail earlier. NCDWQ required the town to install a sharp
crested weir plate on the post aeration effluent weir for this purpose. This effectively raised the
water level in the chlorine contact basin. In fact the contact basin influent sharp crested weir is
sometimes submerged at peak flow.
Benson recently repaired its dechlorination system feed equipment. As a part of this
project, the chlorinators and contact chamber influent flow meter were repaired. This allowed
the chlorination system to once again be paced proportional to flow. The chlorine gas leak
detector has also being replaced.
4.3.10 Dechlorination System
The dechlorination system at the plant is designed to remove total residual chlorine from
the filter backwash tank effluent prior to discharge into the post aeration tank and subsequently
to the receiving stream. The design description of the dechlorination system is given as follows:
36

Item
Info.
Chemical use for dechlorination
Solution tank size, gallons
Number of metering pumps
sodium sulfite
Metering pump capacity, gallons per hour (ph)
250
2
Table 4.2 — Existing Dechlorination System
0 to 1.5
The metering pumps are paced with flow. An on-line effluent chlorine residual analyzer
is provided to monitor total chlorine residual in the effluent. The system was recently repaired.
4.3.11 Aerated Sludge Stabilization/Storage Basin
The existing 3,247,000 gallon capacity aerated sludge stabilization/holding basin is
equipped with three 15 horsepower (hp) surface aerators for facultative sludge stabilization and
odor control. The total aeration capacity provided is 13.8 hp/MG. The aerators are not designed
to provide a complete mix environment in the basin. Considering the total basin volume of
3,247,000 gallons (434,060 CF) and aeration requirements for complete mix of 1.0 hp/1,000 CF,
the total aeration horsepower required for complete mix operation will be approximately 434
horsepower. The other alternative would be to provide floating mixers for mixing need. The total
mixer horsepower required is estimated to be 120 hp (twelve 10 hp mixers). Provision of such
aeration/mixing capacities for complete mix operation will pose an undue economic burden on
the town and a waste of energy for the following reasons:
• The existing extended aeration (oxidation ditch) type activated sludge system is
operated at high sludge age, and the sludge is partially stabilized in the system prior to
being wasted to the aerated sludge basin.
• The aerated sludge basin provides facultative long-term sludge stabilization.
37

• Prior testing of the biosolids in the aerated sludge basin has shown compliance with
the requirements of 40 CFR Part 503 regulations. Compliance options used are ceiling
concentrations of pollutants, Class B pathogen reduction (Alternative 1 or 2), and
vector attraction reduction (Option 3, 6, 9, or 10).
Rain water and supernatant are periodically drained by gravity to the equalization basins.
This water is then pumped back to the plant for treatment.
Refer to Appendix 4.2 for a copy of the town's sludge management plan.
4.3.12 Biosolids Disposal
According to the letter from DWQ to the Town of Benson dated February 27, 2004, the
town currently has remaining one (1) 18.20-net acre land application site under its Land
Application of Residual Solids Permit No. WQ0012514 (see copy of the letter and permit in
Appendix 4.2). The permit allows for the land application of 250 dry tons of residuals.
At a BOD5 concentration of 135 mg/L used for design, and at a flow rate of 1.9 mgd, it is
anticipated that approximately 265 dry tons of residuals will be produced per year. This exceeds
the current permit allocation. As stated in the interim improvements PER, the town will need to
acquire additional land and increase the limits of its permit.
The town last land -applied residuals in 2002 and 2003. In 2002, the total quantity
applied was 25.14 dry tons to the then -available 57.8 acres. In 2003, the quantity was 15.12 dry
tons to 34.8 acres. These represent 10% and 6% of the currently allowable 250 dry tons per year.
It is thought that the WWTP could increase its application of residuals to maximize its permit
allotment. While the absolute permit maximum is 250 tons, there are other permit limits —such
as constituent Ceiling Concentrations, Cumulative Pollutant Loading Rates (CPLRs), and Plant
Available Nitrogen (PAN) —that could potentially be reached prior to the absolute maximum.
38

To determine the maximum quantity of residuals that the town's permit allows, it is
necessary to analyze lab results on residuals from 2002 and 2003 (see Appendix 4.3). Aside
from elevated levels of Molybdenum in 2002—whose concentration dropped well below the
ceiling limit in 2003—lab results from these two (2) years suggest that the limiting factor in land
application is Plant Available Nitrogen (PAN).
In 2002, the PAN concentration measured in the residual was 14.68 lb/ton on a dry
weight basis. At this concentration, the permit maximum of 250 dry tons could be achieved (or
theoretically exceeded) on three (3) individual crops — Bermuda Grass, Sorghum or Sudex
(Silage), and Fescue — or a combination of these crops with others.
For 2003, the PAN concentration in the residuals was approximately one-half of the 2002
concentration, or 7.37 lb/ton on a dry, weight basis. The majority of crops could receive at least
the permit maximum of 250 dry tons and not exceed the PAN limits.
The 2002 and 2003 lab results suggest that the land application of WWTP residuals could
be increased to the maximum quantity of 250 dry tons per year on several crops and remain
below PAN limits. As stated above, additional land will need to be acquired to receive the
anticipated total of 265 dry tons. It is anticipated that PAN would again be the limiting factor in
the decision of how much land is needed under a renewed permit to meet the additional quantity.
39

5.0 INTERIM WASTEWATER TREATMENT FACILITIES
5.1 Description
As noted previously, the Town of Benson is currently performing interim improvements
to its wastewater treatment plant to increase its capacity to 1.97 mgd (permitted capacity to 1.9
mgd). A separate PER, published on March 29, 2005 and subsequently amended on April 29,
2005, October 14, 2005, February 3, 2006, and March 1, 2006 has been prepared and submitted
to DWQ. Figure 5.1 shows the schematic site plan for these interim improvements. A detailed
description of these interim improvements is listed below.
5.1.1 Sewer Outfall Manholes and Diversion Box
The plant is currently served by a sewer outfall eighteen (18) inches in diameter. In order
to raise the hydraulic grade line to 4.925 mgd, some of the manholes just upstream of the WWTP
are to be raised during the interim improvements. In addition, the existing diversion box
overflow weir is to be modified to divert flows above 4.925 mgd to the WWTP's equalization
basins.
5.1.2 Mechanical Screen/Manually Cleaned By -Pass Screen
This unit was deemed suitable for use during the interim improvements period. Its
process description remains the same as that listed above in Section 4.3.1. The WWTP's
comminutor, alluded to above, is to be removed during the interim improvements.
40

INTERIM IMPROVEMENTS
MIME NEW STRUCTURE
UPGRADE TO EXISTING x
NEW
CLARIFIER
No 5
CLARIFIER
No 5
FEBRUARY 2007
TOWN OF BENSON
NORTH CAROLINA
VWVfP EXPANSION
ALTERNATIVES
TT
THE WOOTEN COMPANY
ENGINEERING PLANNING AnCHITECTURE
120 North Boylan Avenue Raleigh NC 27603-1423
919 828 0531 tax 919 834 3589
1
ITFALL
JTFALL
BOX SLUDGE AERATION BASIN
INTIEMATIC
1.9
ce
DO
ISCHARGE

5.1.3 Grit Removal System
To allow for higher hydraulic grade line at 4.925 mgd, the walls of the grit chamber are
to be raised nine (9) inches during the interim improvements. The grit removal unit itself
remains was determined adequate for use during the interim period and is the same as that
described in Section 4.3.2.
5.1.4 Influent Wastewater Pump Station
The two (2) existing 3 hp, 1,370 gpm screw pumps installed in 1977 and described in
Section 4.3.3 are to be replaced during the interim improvements with two (2) new 5 hp, 1,750
screw pumps.
5.1.5 Modified BNR Activated Sludge System
Under the interim improvements, the oxidation ditches are to be operated as before in
BNR mode. All raw sewage and return sludge will go to the middle, anoxic ditch for
denitrification. The flow then moves from this middle ditch to the two (2) outer, aerobic ditches
for BOD5 removal and nitrification. The internal recycle (8 mgd) will continue between the
anoxic and aerobic zones.
5.1.5.1 Oxidation Ditch Brushes
Upgrades during the interim period include the replacement of four (4) 7.5 hp brush rotor
drives with 15 hp drives in each of the two (2) outer, aerobic ditches. The existing brushes on
these rotors will be kept in use. In addition, one (1) new 15 hp brush rotor is to be added to each
of the two (2) outer, aerobic ditches. No brush rotor changes are needed in the middle ditch.
The net result of the interim improvements will be that each of the two (2) outer, aerobic
ditches will contain four (4) 15 hp rotors with existing brushes and one (1) new 15 hp rotor with
new brushes. In the middle, anoxic ditch there will continue to be four (4) 7.5 hp brush rotors.
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5.1.5.2 Lime Feed System
The lime feed system as described in section 4.3.5 will remain unchanged during the
interim improvements period. As noted in that section, the town is keeping the system for
operational readiness should lime feed be needed to optimize nitrification in the oxidation ditch
system.
5.1.5.3 Alum Feed System For Chemical Phosphorus Removal
The system as described in Section 4.3.6 will remain unchanged by the interim
improvements.
5.1.5.4 Splitter Box No. 1
The interim improvements provide for the construction of a new Splitter Box No. 1 to
collect the mixed liquor effluent from the three (3) oxidation ditches. This new box will
discharge to a thirty-six (36) inch pipe that takes flow to the second new splitter box.
5.1.5.5 Splitter Box No. 2
The interim changes also include a new Splitter Box No. 2 to receive flows from Splitter
Box No. 1. This second box is to distribute flows to the five (5) secondary clarifiers.
5.1.6 Secondary Clarifiers
The interim improvements are to add a fifth secondary clarifier. Clarifier No. 5 is to
measure fifty (50) feet in diameter and have a side water depth of fourteen (14) feet. The design
combined surface overflow rate after the interim upgrades is 340 gpd/sf at average flow.
43

5.1.7 Return Activated Sludge (RAS)
The interim upgrades also include enhancements to the RAS flow control box. The
existing plug valve is to be relocated, and a new weir box and staff gate are to be added for flow
control.
5.1.8 Filter Lift Station
All three (3) of the existing filter lift pumps, noted above in Section 4.3.7, will be
upgraded in the interim period. The three (3) pumps' capacities will be expanded to 2,300 gpm
and 30 hp each by replacing their impellers, motors, and variable speed controls.
5.1.9 Tertiary Filtration System
The interim improvements call for the evaluation of each tertiary filter. Also included is
the replacement of the dual media and the replacement of the filter face piping and valves with
larger diameter pipe and valves. After the interim improvements, the average filter rate will be
2.3 gpm/sf.
5.1.10 Chlorination System
As part of the interim improvements, the chlorination system may be modified in several
ways. First, the inlet weir, outlet weir, and contact chamber walls may be modified to account
for the added flows and to ensure the weirs are no longer submerged during operations. In
addition, chlorinators and metering pumps may be upsized to account for additional flows during
the interim period.
5.1.11 Dechlorination System
The dechlorination system has been repaired and is operating as outlined in Section
4.3.10 above.
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5.1.12 Aerated Sludge Stabilization / Storage Basin
During the interim timeframe, the aerated sludge stabilization / storage basin is to remain
as it is described in Section 4.3.11.
5.1.13 Biosolids Disposal
It is recommended that the town increase its disposal of biosolids to its permitted limit
and seek additional area for disposal of the additional biosolids to be produced from the plant
expansion. See comments above in Section 4.3.12 and Preliminary WWTP Expansion Process
Calculations in Appendix 7.1.
5.1.14 Yard Piping
The yard piping from the influent lift station to the chlorine contact chamber is to be
paralleled and in some areas replaced to handle the interim improvements' increased capacity of
1.97 mgd.
5.1.15 Electrical
Existing normal and standby power sources have sufficient spare capacity to
accommodate the increased pumping and aeration needs of the interim upgrades.
45

6.0 DESIGN BASIS
6.1 Influent Wastewater Flows and Characteristics
The subject of this report is the expansion of the Benson WWTP to a treatment capacity
of 3.0 mgd, or, in lieu of expansion, the construction of improvements to enable the town to
divert as much as 1.1 mgd from the WWTP for treatment elsewhere. It is proposed to complete
this work by 2020. As noted above, the town is expanding the treatment capacity at the plant to
1.97 mgd (1.9 mgd permitted capacity) prior to the ultimate expansion to 3.0 mgd. Both capacity
upgrades are based on the influent wastewater flows outlined above in Section 3.2.5 and Figure
3.2. For the influent wastewater characteristics used for both upgrades, refer to the performance
evaluation in Section 4.2 above and the existing NPDES permit in Appendix 2.1.
The existing plant average monthly capacity is 1.5 mgd. The town currently has
sufficient nitrogen discharge allocation to allow it to expand to 3.0 mgd using currently available
technology.
The performance evaluation reported earlier reveals that the current influent wastewater
characteristics are quite a bit weaker than typical domestic municipal wastewater. This is due
both to low strength wastewater from PGI and I/I. Further analysis revealed that it is prudent to
use flow and organic load peak factors of 2.5 and 1.5, respectively, based on peak day to yearly
averages.
It is assumed that other organic wastewater characteristics will be proportional to BOD5.
The current (2006) yearly average BOD5 is 110 mg/l. Town staff reports PGI flows to average
about 0.34 mgd with an average BOD5 on the order of 30 mg/l. (Note that PGI's updated
industrial pretreatment permit allows it to discharge up to 0.400 mgd at 100 mg/1 BOD5.) I/I was
previously reported to average about 0.27 mgd (BOD5 = 0). It is assumed that all other current
wastewater sources and all future wastewater sources will contribute an average BOD5 of 200
mg/l. Still, one can see from the data from 2004 to 2006 that influent BOD5 is increasing. This
is most likely due to successful efforts at reducing I/I. For conservatism in future planning, a
46

design influent BOD5 of 200 mg/1 is used, though one can see from the concentrations above that
actual influent BOD5 may be less. The design influent characteristics chosen for the 3.00 mgd
plant are summarized in Table 6.1 below.
Item
Value
Average Wastewater Flow, mgd
3.0
Maximum Wastewater Flow, mgd
6.0
Peak Wastewater Flow, mgd
7.5
BOD5, mg/1
200
TSS, mg/1
200
TKN (total Kjeldahl nitrogen), mg/1
40
NH3-N, mg/1
27
Total P, mg/1
6
Total Alkalinity as CaCO3, mg/1
120
pH, standard units
6.8 — 8.2
Temperature, degrees Celsius
Winter Min. = 10
Summer Max. = 28
Table 6.1— Proposed Design Influent Wastewater Characteristics
6.2 Effluent Limitations
On behalf of the Town of Benson, The Wooten Company wrote the Division of Water
Quality (DWQ) on June 25, 2001 to request speculative limits for increasing the discharge to
Hannah Creek to 3.0 mgd. (See Appendix 6.1.) In its response dated January 23, 2006, DWQ
refused to issue speculative limits to this discharge quantity due to the impairment of Hannah
Creek. (See Appendix 6.2.) As noted in the DWQ letter, Hannah Creek was considered
impaired for dissolved oxygen (DO).
The exact cause of Hannah Creek's impairment is not known. North Carolina's 2006
Draft 303(d) List lists a potential source to be a "Major Municipal Point Source." However,
subsequent to the town's receipt of the DWQ letter refusing speculative limits, the town began
47

monitoring DO levels in the creek at different locations. Preliminary DO sampling data obtained
by the town indicate low DO levels even upstream of the WWTP. It is possible that stormwater
runoff from agricultural and animal operations upstream of the plant may be contributing factors.
In order to discuss the impairment of Hannah Creek and its impact on the expansion of
the Benson WWTP, the Town of Benson and The Wooten Company (TWC) met with
representatives from DWQ on two occasions. The first meeting was held on February 17, 2006
with representatives from DWQ's NPDES Eastern Unit and the Classifications and Standards
Unit. Items discussed at this first meeting included the following:
• Both Benson and TWC expressed consternation over the inclusion of Hannah Creek
on the 303(d) List and the perceived lack of appreciable notice given to the town,
particularly considering the gravity of the impairment's impact on Benson's growth.
• On behalf of Benson, TWC asked the state if it were possible to re-classify Hannah
Creek from its status as a Class C stream to a swamp. Hannah Creek's flows were
noted as minimal. In addition, swamps have a lower DO standard than streams.
• According to DWQ, re-classification of Hannah Creek would require the completion
of a Use Attainability Analysis (UAA) for EPA. The UAA would have to argue that
the creek was currently mis-classified. This process could take two (2) years to
complete. The state added that it had never dealt with a UAA nor had it ever re-
classified a stream.
• The state suspects that it would not be issuing speculative limits for the Cape Fear
until its water quality model was completed.
A second meeting was held with the state on March 3, 2006. Representatives from the
Town of Benson and TWC were joined by representatives from the DWQ's Planning Section,
the NPDES Program's Eastern Unit, the Modeling and TMDL Unit, and the Basinwide Planning
Program. Topics from this second meeting included:
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• TWC noted that in 2002 DWQ had written that it would continue to work with Benson
to improve dissolved oxygen (DO) levels in Hannah Creek. TWC noted that no such
work had been done in coordination with the town.
• DWQ considers a stream impaired for DO if more than 10% of its samples are below 4
mg/L.
• DWQ acknowledged that North Carolina's 2004 draft 303(d) list has not yet been
approved by the United States Environmental Protection Agency (USEPA). USEPA
believes that the state's list is not stringent enough.
• DWQ noted that Hannah Creek from the WWTP to NC 96 would be on the 2008
303(d) list for two impairments. It will be listed as a Category 5 water impaired for
DO and a Category 6 water for biological integrity. A Category 5 water requires the
development of a Total Maximum Daily Load (TMDL). A Category 6 water is
considered impaired based on biological data, with no cause known.
• Benson presented DO data that the town had been collecting since February 2006.
The town's measurements showed DO levels higher than those recorded for use by the
state. Also, Benson noted that the data suggested that DO levels are often lower
upstream of the WWTP than downstream. The town stated that the cause of DO
depletion may be runoff from nonpoint agricultural and cattle operations elsewhere
along Hannah Creek and its tributaries.
• TWC asked if the NPDES unit would approve a 3.0 mgd discharge from the Benson
WWTP for Hannah Creek if the DO impairment were removed. DWQ said it likely
would not approve the additional discharge due to the biological impairment.
• TWC presented four effluent discharge options for Benson WWTP: Hannah Creek, the
Neuse River main stem, Mingo Swamp in the South River Subbasin of the Cape Fear,
and direct discharge to the Cape Fear River.
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• DWQ said it did not consider Hannah Creek a likely option due to its current Category
5 and imminent Category 6 impairment. Direct discharge to the Neuse is a viable
option. Models for the Neuse River are complete and can be used to consider a
speculative limit request from the NPDES unit. DWQ would likely not consider
Mingo Swamp due to its low flows. DWQ is currently completing models for the
Cape Fear River and would not issue speculative limits until those models are
complete
In short, Hannah Creek was listed on the state's 2004 303(d) List as impaired for low
DO. This listing remained the same for the state's draft 2006 list. According to DWQ, Hannah
Creek will be listed as again in 2008, only it will be listed as impaired for both low DO and
biological integrity.
Hannah Creek's listing makes it an unlikely candidate — at least in the short term — to
serve as the receiving stream for the additional 1.1 mgd expected for Benson WWTP. Still, since
the town's DO monitoring continues, it is not impossible that its impairment could be lifted and
the stream could be permitted to receive additional effluent. Because of this possibility, this
report considers Hannah Creek as a possible receiving stream. Other effluent discharge options
include discharge to the Neuse River, discharge to Mingo Swamp in the South River Subbasin of
the Cape Fear, and land application.
It is also possible that approximately 1.1 mgd of influent could be diverted at the
headworks of the Benson WWTP and pumped to other systems in the region, such as Harnett
County or Dunn, for treatment. Preliminary discussions with these two local government took
place in the fall of 2006.
This report studies all of six (6) of these alternatives in the sections that follow.
Graphically, these alternatives are portrayed in Figure 6.1 below.
50

Figure 6.1— Map of Alternatives

7.0 ALTERNATIVES
7.1 Optimum Operation of the Existing Waste Treatment Facility
The consideration of an alternative for optimizing the performance of the existing
facilities is a required step in any upgrading and expansion scenario. A performance evaluation
of the overall treatment plant and unit operations/processes was given in Sections 4 and 5 above.
It indicated that the existing plant is operating at optimum efficiency and is in compliance with
most effluent limitations given in the both the existing NPDES permit and the speculative
NPDES permit limits. However, shortcomings were noted in several areas, especially with
respect to the new reclaimed water permit and the planned increase in plant flows. For a
treatment expansion to 3.0 mgd, neither the existing WWTP nor the improved WWTP is
sufficient for the following reasons:
• The mechanical bar screen has reached the end of its effective service life.
• The grit chamber is worn out and undersized for the increased flows.
• The existing diversion box at the head of the plant is inadequate as it currently
allows influent to bypass grit removal and screening at high flows and go directly
to the equalization basin.
• The Parshall flume is of insufficient size to measure the increased flows.
• The influent lift station, upgraded during the interim improvements, will be of
insufficient capacity to handle the design peak flow of 7.5 mgd.
• The splitter box to the oxidation ditches is undersized for the increased flows.
• The oxidation ditches have insufficient volume for the future flows.
• The aerator brushes are expected to be near the end of their effective life.
• More clarifier surface area is needed to handle the projected average design flow
of 3.00 mgd.
• The filter lift pumping station will need to be paralleled with a new pumping
station to account for the additional flows.
• Some sections of yard piping are insufficient to convey additional flows.
52

• The tertiary filters, improved in the interim, are not sufficient for the required de -
nitrification at 3.0 mgd.
7.2 No Action Plan
The "No Action Plan" means to do nothing. This alternative consists of not making any
corrective actions necessary for safe, reliable, and efficient plant operation and for compliance
with regulatory requirements when the plant annual daily flow reaches 80% and 90% of its
permitted flow. The "No Action Plan" would also discourage residential, commercial and
industrial growth in Benson and Johnston County. For these various reasons, the "No Action
Plan" is eliminated from further consideration.
7.3 Wastewater Reuse
A small water reuse project using reuse water from the Benson WWTP is currently being
used. Refer to the permit in Appendix 4.4. This project, done in conjunction with the Johnston
County Schools, currently makes use of up to 17,020 gpd of reclaimed municipal wastewater on
an annual basis. It provides irrigation water for athletic fields at South Johnston High School.
Other potential water reuse recipients were investigated as part of this report. The Town
of Benson's Planning and Zoning Department was asked if there were imminent commercial or
industrial developments at or near the town that might create a demand for reuse water. It was
learned that there are no such projects anticipated. At The Wooten Company's (TWC) request,
the department rendered a list of potential reuse users to TWC on October 24, 2005. These
potential users were contacted by phone as part of this report. This preliminary investigation,
detailed below, failed to reveal other likely water reuse customers.
First, Johnston County Schools was contacted on November 1, 2005 to gauge its interest
in receiving additional reuse water. The school system had previously stated its desire to obtain
reuse water to irrigate athletic fields at Benson Middle School. However, in a phone
conversation with a school representative, it was learned that the system wanted to assess the
53

current project at South Johnston High School over a longer period of time before committing to
additional projects. Therefore, additional reuse by the school system is not pursued at this time.
The one large, water -using industry within the Benson system, Polymer Group,
Incorporated (PGI), was considered for water reuse. PGI already recycles a great deal of its
process water. Since its products include pharmaceutical -grade materials, it is unlikely that
reclaimed municipal wastewater would be acceptable for its purposes. Therefore, PGI was
eliminated as a potential customer for reuse water.
Reedy Creek Golf Course was contacted on November 1, 2005. The golf course is
located approximately 7.5 miles (measured in a straight line) from the WWTP and was
considered a possible recipient of reuse water. However, it was discovered in a phone
conversation with a course representative that Reedy Creek irrigates its green areas with water
from its own storage ponds. In addition, it has two wells for reserve that it rarely utilizes. Thus,
its current potential for water reuse is very low.
Martin Marietta Aggregates was contacted on October 25, 2005. The industry operates a
quarry approximately 2.25 direct miles from the Benson Plant. It, too, has its own on -site
impoundments to meet its water needs and is not a likely candidate for reuse water at this time.
Benson Veneer, a furniture products manufacturer located approximately 2.67 direct
miles from the WWTP in the southern part of the Town of Benson, was also called on November
1, 2005. However, the company stated in a phone conversation that its process did not require a
significant quantity of water and was therefore eliminated from further consideration.
Finally, Benson's Parks and Recreation Department was contacted on October 26, 2005
to see if the town itself might use reuse water. No such need was anticipated.
In conclusion, from the information obtained during contacts with local businesses and
government agencies, there appears to be little demand for reuse water supplied by the Benson
WWTP. Thus, reuse water as a significant or viable option for the plant's expanded effluent is
eliminated from further consideration at this time.
54

7.4 Alternative Wastewater Treatment Systems
In the following sections, six (6) alternative wastewater treatment systems have been
evaluated to determine the most cost-effective solution to the Town of Benson's present and
projected wastewater treatment needs. See Appendix 7.1 for plant expansion process
calculations.
The primary objectives considered in evaluation of the alternatives are listed as follows:
• A high degree of wastewater treatment must be achieved to meet the established
effluent limitations and USEPA and NCDWQ sludge regulations.
• Make maximum use of the existing facilities.
• USEPA/NCDWQ reliability criteria must be met at reasonable costs.
• Construction of the treatment units should be arranged in logical stages.
• Provision of flexibility in design and operation of unit operations/processes
should be incorporated into the plant.
• Operator's familiarity with the operation of unit operation or processes should be
considered.
• Operating cost of treatment facilities should be kept to a minimum.
• Flexibility should be afforded for future upgrades, expansions, or application of
technology at a later date to provide for the reclaiming or recycling of water or
otherwise eliminating the discharge of pollutants.
In addition to the above objectives, when selecting potential sites for disposal of effluent by
land application for non -discharge alternatives, the following factors must be taken into
consideration:
• A site should be selected that has soil groups most suited for the land application
processes under consideration.
55

• The site should not conflict with the present and anticipated land use and should
reinforce the adopted land use plans.
• The site should be within a reasonable transport distance from the source of
wastewater.
• The site should not endanger sensitive environmental areas such as historic sites
or rare or endangered species areas.
• The site should minimize adverse socio-economic impacts.
• The site should not have geological or groundwater conditions that would
adversely affect the land application treatment process being considered.
• The elevation difference between the site and the source of wastewater should be
kept to a minimum to reduce pumping costs.
• The number and size of the available land parcels should also be considered.
7.4.1 Alternative No. 1 — WWTP Expansion to 3.0 mgd, Expanded Discharge to Hannah
Creek
This alternative considers the upgrade and expansion of the existing wastewater treatment
plant to 3.0 mgd and the discharge of the additional effluent to Hannah Creek. As chronicled in
detail above in Section 6.2, Hannah Creek's impairment and its inclusion on North Carolina's
303(d) List makes this discharge scenario unlikely in the short term. Still, it might be possible if
in -stream monitoring by the town shows improvement in the future.
See Figure 7.1 below for a schematic site plan of the proposed improvements. A detailed
description and cost analysis of this alternative are given below.
7.4.1.1 Description
The principle components of this alternative are as follows:
• Mechanical Bar Screen: Replace existing unit with a new mechanical screen /
manual by-pass screen facilities designed to handle peak flow of 7.5 mgd. The
design screen openings for the mechanical screen and manual by-pass screen will
56

be 1/4-inch and Y2-inch, respectively. The mechanical screen will be equipped with
screenings washing, compacting unit, and bagger for screen collection and
disposal.
• Grit Unit: Replace existing unit with new unit designed to handle peak flow of
7.5 mgd.
• Headworks: Construct new headworks so that all influent, even excess flows to
be sent to equalization basins, is first conveyed through solids screening and grit
removal processes.
• Parshall Flume: Construct new flow measuring device large enough to account
for expanded flows.
• Influent Lift Station: Replace existing lift station with a new pump station
designed to accommodate necessary wet well, pumps, piping, and controls to
handle design peak flow of 7.5 mgd.
• Splitter Box No. 1: Construct new splitter box at the head of each of the three (3)
oxidation ditches to handle the increased flows.
• Oxidation Ditches: Construct vertical walls around the perimeter of each of the
three (3) oxidation ditches to effectively raise their walls. This construction will
provide a total volume of 1.236 MG for each ditch. To safeguard against
potential seepage through the concrete joints of the existing basins due to the load
of the new walls, a sealant of the existing concrete joints will be needed.
Oxidation ditches will continue in BNR mode. Increase internal recycling
pumping capacity to four times the average flow, or a total of 12 mgd. Parallel
existing piping between the outer ditches and inner ditch to allow for the
additional flow of mixed liquor.
• Aerators: Abandon all existing brush aerators and replace with five (5) 20-hp
baffled brush aerators in each of the three (3) oxidation ditches, for a total of
fifteen (15) new aerators.
57

• Splitter Box No. 2: Provide new splitter box to distribute increased flows to what
will be six (6) secondary clarifiers.
• Secondary Clarifiers: Build one new 50-foot diameter x 14-foot side wall depth
clarifier to provide adequate surface area for expanded flows. With the new
clarifier, the average overflow rate would be approximately 386 gpd/sf.
• RAS Pump Station: Convert existing filter lift station to new RAS Pump Station.
• Filter Lift Station: Construct new filter lift station to sit in parallel with existing
station to provide enough capacity for expansion.
• Tertiary Filtration: Upgrade the existing tertiary filters to provide de -nitrification.
Construct parallel filters to provide tertiary filtration and de -nitrification for
additional plant flows. The average filtration rate for the expanded plant would
be 1.7 gpm/sf.
• Anaerobic Tank: Construct new anaerobic tank for biological phosphorus
removal.
• Alum Feed System for Chemical Phosphorus Removal: Continue use of existing
alum feed system for supplemental chemical phosphorus removal on an as -needed
basis.
• Ultraviolet (UV) Disinfection Unit: Construct new UV disinfection unit to meet
disinfection requirements for effluent discharge to surface waters.
• Chlorine Contact, Backwash Water Storage, Dechlorination Chamber, and Post
Aeration Unit: Maintain existing chlorination/dechlorination equipment to treat
reuse water to meet its stricter requirements and to serve as a backup to new UV
disinfection.
• Gravity Outfall: Parallel existing gravity outfall pipe to carry additional design
flows.
• Yard Piping: Additional yard piping will be required to convey flows to the new
process equipment being constructed.
58

• Electrical Improvements: Electrical improvements will be required to
accommodate the increased pumping and aeration needs of the expanded plant.
59

DESIGN LEGEND
NEW STRUCTURE
UPGRADE TO EXISTING
ABANDONED
•t NEW
CLARIFIER
No 8
ICLARIFIER
No
4 �5,
BE
UILD NG
NEW
PUMPING
STATION
1I
} —
ll
•
t I I.
t\ g
�I 1!
LL
\ t�_
=1 1aI 1 I BAERCHSC�I1EEN
rcl 1 II
FEBRUARY 2007 al ( XI >'
r
TOWN OF BENSOI
NORTH CAROLINA
VWVfP EXPANSION
ALTERNATIVES
TY
THE WOOTEN COMPANY
ENGINEERING PLANNING I ARCHITECTURE
120 North Boylan Avenue Raleigh NC 27603-1423
919.820.0531 fax [phone]
RECLAIMED WATER
PUMP STATION
DECHLORINATION
PCS'AERATION
DIVERSION
BOX
GRIT CHAMBER
NEW
HEAOWORKS
//
I
CONTROL
BUILDING
CO9IVERTE11 RAS PS
EXISTING
PUMPING
STATION
SPLITTER
BOX No 2
2{"
cmIIMINurn�
x 7r—iE--7F—x K- x K x--X---x x--M x # x—x
18"
CHLORINE
BUILDING
•
b
4-
PARSHALL
FLUME
1r
NEW DENITRIFICATION FILTERS
�raTaljd. r mosoLsHiEffilikai
EQUALIZATION BASIN
OXimmoN DITOH NO.3
OXIDATION DITCH NO, 2
OXIDATION DITCH NO 1
NEW ULTRAVIOLET
DISINFECTION
BASIN RETURN
ASPHALT ROAD
2' REOLA/MEGYM,TER
ASPHALT ROAD
x—x xc n
30" GRAVITY OUTFALL
21" GRAVITY OUTFALL
FIGURE 7.1
x ]i x-N--x
EFFLUENT PUMP STATION
AND FORCE MAIN
(ALTERNATE No 2 AND 3)
L CONTINUE OUIFALL
(ALTERNATE No 1)
NEW ANAEROBIC TANK
OXIDATION TANK NO2
ANOXIC TANK NO 1
OXIDATION TANK NO 1
SLUDGE AERATION BASIN
PROPOSED WASTEWATER TREATMENT PLANT SCHEMATIC
3.0 MGD (EXPANDED DISCHARGE)

7.4.1.2 Estimated Project Cost
The total estimated project cost is $16,345,000 in 2007 dollars. See Table 7.1 below for
details. See Figure 7.1 for treatment schematic.
Table 7.1— Estimate of Probable Cost for Alternative No. 1,
WWTP Expansion to 3.0 mgd, Expanded Discharge to Hannah Creek
UNIT
EXTENDED
NO.
DESCRIPTION
UNITS
QTY
COST
COST
1
New Headworks
LS
1
$525,000
$525,000
2
New Influent Lift Station
LS
1
$440,000
$440,000
3
Anaerobic Tank
LS
1
$515,000
$515,000
4
Splitter Box into Ox. Ditches
LS
1
$35,000
$35,000
5
Ox. Ditch Upgrades
LS
1
$3,000,000
$3,000,000
6
New Clarifier No. 6
LS
1
$445,000
$445,000
7
RAS Pump Upgrade
LS
1
$65,000
$65,000
8
New Filter Lift Station
LS
1
$485,000
$485,000
9
Modify Ex. Filters for Denitrification
LS
1
$340,000
$340,000
10
New Denitrification Filters
LS
1
$1,700,000
$1,700,000
11
UV Disinfection
LS
1
$370,000
$370,000
12
New Postaeration
LS
1
$115,000
$115,000
13
Chlor / Dechlor Budget (for reuse/emergencies)
LS
1
$55,000
$55,000
14
New 21" Parallel Outfall
LS
1
$275,000
$275,000
r 15
Sludge Facility Improvements
LS
1
$1,100,000
$1,100,000
16
Admin., Control, & Lab Bldg. Improvements
LS
1
$390,000
$390,000
17
Yard Piping
_
LS
1
$245,000
$245,000
18
Electrical (Includes Standby Power)
LS
1
$1,370,000
$1,370,000
19
Misc. Site Work
LS_
1
$1,100,000
$1,100,000
Total Construction Cost
$12,570,000
Engineering & Contingency (30%)
$3,775,000
Total Project Cost
$16,345,000
Note: Costs are preliminary an in 2007 dollars. Do not use for construction.
61

7.4.1.3 Estimated Annual Operation and Maintenance Costs
Table 7.2 — Estimated Total Annual O&M Costs for Alternative No. 1,
WWTP Expansion to 3.0 mgd, Expanded Discharge to Hannah Creek
ITEM
ANNUAL
Salaries, including fringe benefits:
$250,000
Utilities
Electrical
$230,000
Telephone
$3,000
Chemicals
Lime
$3,500
Alum
$1,900
Polymer
$8,800
Chlorine
$4,700
Maintenance and Repairs
Building
$4,000
Equipment
$30,000
Gas and Lubricants
$8,000
Vehicles
$3,500
Materials
$4,500
Equipment and Safety
$9,000
Contingency
$4,700
Contracted Services:
Skilled Services
$70,000
Sludge Disposal
$100,000
County Landfill Fee
$1,400
Travel and Training:
$3,000
Department Supplies:
$8,000
Permit Fees and Dues:
$2,000
Insurance:
$7,000
Capital Reserve:
$33,000
Total Annual Operation and Maintenance Costs
$790,000
62

7.4.1.4 Estimated Salvage Value
The useable life of the capital improvements is estimated to be thirty years. Therefore,
using straight-line depreciation, the salvage value of the improvements at the end of the twenty
year planning period is one-third of its initial value. From Table 7.1 above, the initial capital
investment is $12,570,000. Therefore the salvage value in 2027 is $4,190,000 in 2007 dollars.
7.4.1.5 Estimated Present Worth Cost
The planning period is twenty years. The current USEPA discount rate is 4.875 percent,
compounded annually. The present worth cost is calculated as follows:
Present Worth Cost = $16,150,000 + ($790,000)(P/A, 4.875%, 20 years) —
($4,190,000)(P/F, 4.875%, 20 years) = $16,150,000 + $9,950,000 - $1,617,000 = $24,678,000 —
$24,700,000.
7.4.2 Alternative No. 2 — WWTP Expansion to 3.0 mgd, Expanded Discharge to the Neuse
River
Alternative No. 2 would expand the on -site WWTP facility in the same manner as
Alternative No. 1, but would transfer the treated effluent to the Neuse River for discharge. This
option would require the construction of an effluent pump station and approximately 53,000 LF
of force main approximately 20-inches in diameter to pipe the effluent to the Neuse River
southwest of Smithfield. (See Figure 6.1.)
7.4.2.1 Estimated Project Cost
The total estimated project cost is $21,665,000 in 2007 dollars. See Table 7.3 below for
details. See Figure 7.1 for treatment schematic.
63

Table 7.3 — Estimate of Probable Cost for Alternative No. 2,
WWTP Expansion to 3.0 mgd, Expanded Discharge to the Neuse River
UNIT
EXTENDED
NO.
DESCRIPTION
UNITS
QTY
COST
COST
1
New Headworks
LS
1
$525,000
$525,000
2
New Influent Lift Station
LS
1
$440,000
$440,000
3
Anaerobic Tank
LS
1
$515,000
$515,000
4
Splitter Box into Ox. Ditches
LS
1
$35,000
$35,000
5
Ox. Ditch Upgrades
LS
1
$3,000,000
$3,000,000
6
New Clarifier No. 6
LS
1
$445,000
$445,000
7
RAS Pump Upgrade
LS
1
$65,000
$65,000
8
New Filter Lift Station
LS
1
$485,000
$485,000
9
Modify Ex. Filters for Denitrification
LS
1
$340,000
$340,000
10
New Denitrification Filters
LS
1
$1,700,000
$1,700,000
11
UV Disinfection
LS
1
$370,000
$370,000
12
New Postaeration
LS
1
$115,000
$115,000
13
Chlor / Dechlor Budget (for reuse/emergencies)
LS
1
$55,000
$55,000
14
New Effluent Pumping Station
LS
1
$750,000
$750,000
15
New Force Main to Neuse River
LF
53,000
$65
$3,445,000
16
Sludge Facility Improvements
LS
1
$1,100,000
$1,100,000
17
Admin., Control, & Lab Bldg. Improvements
LS
1
$390,000
$390,000
18
Yard Piping
LS
1
$245,000
$245,000
19
Electrical (Includes Standby Power)
LS
1
$1,544,000
$1,544,000
20
Misc. Site Work
LS
1
$1,100,000
$1,100,000
Total Construction Cost
$16,664,000
Engineering & Contingency (30%)
$ 5,001,000
Total Project Cost
$ 21,665,000
Note; Costs are preliminary an in 2007 dollars. Do not use for construction.
64

7.4.2.2 Estimated Annual Operation and Maintenance Costs
Table 7.4 — Estimated Total Annual O&M Costs for Alternative No. 2,
WWTP Expansion to 3.0 mgd, Expanded Discharge to th
ITEM
ANNUAL
Salaries, including fringe benefits:
$250,000
Utilities
Electrical
$255,000
Telephone
$3,000
Chemicals
Lime
$3,500
Alum
$1,900
Polymer
$8,800
Chlorine
$4,700
Maintenance and Repairs
Building
$4,000
Equipment
$35,000
Gas and Lubricants
$10,000
Vehicles
$3,500
Materials
$4,500
Equipment and Safety
$9,000
Contingency
$5,700
Contracted Services:
Skilled Services
$75,000
Sludge Disposal
$100,000
County Landfill Fee
$1,400
Travel and Training:
$3,000
Department Supplies:
$8,000
Permit Fees and Dues:
$2,000
Insurance:
$7,000
Capital Reserve:
$38,000
Total Annual Operation and Maintenance Costs
$833,000
65

7.4.2.3 Estimated Salvage Value
The life of the force main is estimated to be forty years. The useable life of the capital
improvements save the force main is estimated to be thirty years. Therefore, using straight-line
depreciation, the salvage value of the force main at the end of the twenty year planning period is
one-half its value, and the value of the improvements at the end of the same period is one-third
of its initial value. From Table 7.3 above, the initial cost of the force main is $3,445,000. The
initial capital investment for the other improvements is $13,219,000. Therefore the salvage
value in 2027 is $6,129,000 in 2007 dollars.
7.4.2.4 Estimated Present Worth Cost
The planning period is twenty years. The current USEPA discount rate is 4.875 percent,
compounded annually. The present worth cost is calculated as follows:
Present Worth Cost = $21,665,000 + ($833,000)(P/A, 4.875%, 20 years) —
($6,129,000)(P/F, 4.785%, 20 years) = $21,665,000 + $10,492,000 - $2,366,000 = $29,791,000
—> $29,800,000.
7.4.3 Alternative No. 3 — WWTP Expansion to 3.0 mgd, Expanded Discharge to Mingo
Swamp
Alternative No. 3 would also expand the WWTP in the same manner as Alternative No.
1, but would transfer the treated effluent to Mingo Swamp for discharge. This option would
require the construction of an effluent pump station and approximately 26,000 LF of force main
to pipe the effluent to Mingo Swamp to the southwest of Benson. (See Figure 6.1.)
7.4.3.1 Estimated Project Cost
The total estimated project cost is $18,953,000 in 2007 dollars. See Table 7.5 below for
details. See Figure 7.1 for treatment schematic.
66

Table 7.5 — Estimate of Probable Cost for Alternative No. 3,
WWTP Expansion to 3.0 mgd, Expanded Discharge to Mingo Swamp
UNIT
EXTENDED
NO.
DESCRIPTION
UNITS
QTY
t COST
COST
1
New Headworks
LS
1
$525,000
$525,000
2
New Influent Lift Station
LS
1
$440,000
$440,000
3
Anaerobic Tank
LS
1
$515,000
$515,000
4
Splitter Box into Ox. Ditches
LS
1
$35,000
$35,000
5
Ox. Ditch Upgrades
LS
1
$3,000,000
$3,000,000
6
New Clarifier No. 6
LS
1
$445,000
$445,000
7
RAS Pump Upgrade
LS
1
$65,000
$65,000
8
New Filter Lift Station
LS
1
$485,000
$485,000
9
Modify Ex. Filters for Denitrification
LS
1
$340,000
$340,000
10
New Denitrification Filters
LS
1
$1,700,000
$1,700,000
11
UV Disinfection
LS
1
$370,000
$370,000
12
New Postaeration
LS
1
$115,000
$115,000
13
Chlor / Dechlor Budget (for reuse/emergencies)
LS
1
$55,000
$55,000
14
New Effluent Pumping Station
LS
1
$420,000
$420,000
15
New Force Main to Mingo Swamp
LF
26,000
$65
$1,690,000
16
Sludge Facility Improvements
LS
1
$1,100,000
$1,100,000
17
Admin., Control, & Lab Bldg. Improvements
LS
1
$390,000
$390,000
18
Yard Piping
LS
1
$245,000
$245,000
19
Electrical (Includes Standby Power)
LS
1
$1,544,000
$1,544,000
20
Misc. Site Work
LS
1
$1,100,000
$1,100,000
Total Construction Cost
$14,579,000
Engineering & Contingency (30%)
$4,374,000
Total Project Cost
$18,953,000
Note: Costs are preliminary an in 2007 dollars. Do not use for construction.
67

7.4.3.2 Estimated Annual Operation and Maintenance Costs
Table 7.6 — Estimated Total Annual O&M Costs for Alternative No. 3,
WWTP Expansion to 3.0 mgd, Expanded Discharge to Mingo Swam
ITEM
ANNUAL
Salaries, including fringe benefits:
$250,000
Utilities
Electrical
$252,000
Telephone
$3,000
Chemicals
Lime
$3,500
Alum
$1,900
Polymer
$8,800
Chlorine
$4,700
Maintenance and Repairs
Building
$4,000
Equipment
$34,000
Gas and Lubricants
$9,500
Vehicles
$3,500
Materials
$4,500
Equipment and Safety
$9,000
Contingency
$5,200
Contracted Services:
Skilled Services
$75,000
Sludge Disposal
$100,000
County Landfill Fee
$1,400
Travel and Training:
$3,000
Department Supplies:
$8,000
Permit Fees and Dues:
$2,000
Insurance:
$7,000
Capital Reserve:
$35,000
Total Annual Operation and Maintenance Costs
$825,000
68

7.4.3.3 Estimated Salvage Value
The life of the force main is estimated to be forty years. The useable life of the capital
improvements save the force main is estimated to be thirty years. Therefore, using straight-line
depreciation, the salvage value of the force main at the end of the twenty year planning period is
one-half its value, and the value of the improvements at the end of the same period is one-third
of its initial value. From Table 7.5 above, the initial cost of the force main is $1,690,000. The
initial capital investment for the other improvements is $12,889,000. Therefore the salvage
value in 2027 is $5,141,000 in 2007 dollars.
7.4.3.4 Estimated Present Worth Cost
The planning period is twenty years. The current USEPA discount rate is 4.875 percent,
compounded annually. The present worth cost is calculated as follows:
Present Worth Cost = $18,953,000 + ($825,000)(P/A, 4.875%, 20 years) —
($5,141,000)(P/F, 4.875%, 20 years) = $18,953,000 + $10,391,000 - $1,984,000 = $27,360,000
$27,400,000.
7.4.4 Alternative No. 4 — WWTP Expansion to 3.0 mgd, Expanded Discharge Via Land
Application
This alternative considers the upgrade and expansion of the existing wastewater treatment
plant to 3.0 mgd. The plant will continue to discharge tertiary treated effluent to Hannah Creek
under its NPDES permit at 1.9 mgd. The additional 1.1 mgd in flow will be disposed of by land
application at agronomic rates. See Figure 7.2 for a schematic site plan of the proposed
improvements at the plant site. See Figure 7.3 for a schematic site plan of the land application
site.
The pump stations, force main, storage lagoon, and spray fields will be sized to account
for 1.1 mgd of average flow. Options to purchase additional, contiguous land for future storage
and spray fields may be obtained. However, the cost of these options is not included herein. A
detailed description and cost analysis of this alternative are given below.
69

DESIGN LEGEND
NEW STRUCTURE
UPGRADE TO EXISTIN
ABANDONED
7
NEW
CLARIFIER
No
.\
FEBRUARY 2007I
TOWN OF BENSON
NORTH CAROLINA
VWVTP EXPANSION
ALTERNATIVES
TT
THE WOOTEN COMPANY
ENGINEERING PLANNING ARCHITECTURE
120 North Boylan Avenue Raleigh NC 27603-1423
919.828.0531 tax 919.834.3589
4
• =I
•3I
OUTFALL
FIGURE 7.2
•
14n FORCE MAIN TOg.
STORAGE LAGOON AT
SPRAY APPLICATION SITE
OUTFALL
OXIDATION TANK NO 1
SLUDGE AERATION BASIN
F SCHEMATIC
3

TOWN OF BENSON
WASTEWATER TREAT
FEBRUARY 2007
TOWN OF BENSON
NORTH CAROLINA
VWVfP EXPANSION
ALTERNATIVES
THE WOOTEN COMPANY
ENGINEERING I PLANNING I ARCHITECTURE
120 North Boylan Avenue Raleigh NC 27603-1423
919,828.0531 fax [phone]
FIGURE 7.3
- 70 ACRE
IRRIGATION
POND
-- 450 ACRE
TOTAL SITE
W/ BUFFERS
- 305 ACRE
SPRAY
IRRIGATION
FIELD

7.4.4.1 Description
The principal components of this alternative are as follows:
• Mechanical Bar Screen: Replace existing unit to account for monthly average
flow of 3.0 mgd.
• Grit Unit: Replace existing unit with new unit.
• Headworks: Construct new headworks so that all influent, even excess flows to
be sent to equalization basins, is first conveyed through solids screening and grit
removal processes.
• Parshall Flume: Construct new flow measuring device large enough to account
for expanded flows.
• Influent Lift Station: Replace existing lift station to accommodate design peak
flow of 7.5 mgd.
• Splitter Box No. 1: Construct new splitter box at the head of each of the three (3)
oxidation ditches to handle the increased flows.
• Oxidation Ditches: Construct vertical walls around the perimeter of each of the
three (3) oxidation ditches to effectively raise their walls. This construction will
provide a total volume of 1.236 MG for each ditch. To safeguard against
potential seepage through the concrete joints of the existing basins due to the load
of the new walls, a sealant of the existing concrete joints will be needed.
Oxidation ditches will continue in BNR mode. Increase internal recycling
pumping capacity to four times the average flow, or a total of 12 mgd. Parallel
existing piping between the outer ditches and inner ditch to allow for the
additional flow of mixed liquor.
• Aerators: Abandon all existing brush aerators and replace with five (5) 20-hp
baffled brush aerators in each of the three (3) oxidation ditches, for a total of
fifteen (15) new aerators.
72

• Splitter Box No. 2: Provide new splitter box to distribute increased flows to what
will be six (6) secondary clarifiers.
• Secondary Clarifiers: Build one new 50-foot diameter x 14-foot side wall depth
clarifier to provide adequate surface area for expanded flows. With the new
clarifier, the average overflow rate would be approximately 386 gpd/sf.
• RAS Pump Station: Convert existing filter lift station to new RAS Pump Station.
• Anaerobic Tank: Construct new anaerobic tank for phosphorus removal.
• Yard Piping: Additional yard piping will be required to convey flows to the new
process equipment being constructed.
• Electrical Improvements: Electrical improvements will be required to
accommodate the increased pumping and aeration needs of the expanded plant.
• Secondary Effluent Transfer Pumps: Provide three (3) secondary effluent transfer
pumps, each rated at 450 gpm, for transferring secondary effluent to the effluent
storage lagoon at the land application site. One (1) of the pumps will be designed
to serve as a standby unit.
• Secondary Effluent Transfer Force Main: Provide approximately 16,500 if of 14-
inch diameter ductile iron force main to transfer the secondary effluent from the
plant to the effluent storage lagoon at the land application site.
• Secondary Effluent Storage Lagoon: Provide a lagoon for storage of effluent
when land application cannot take place due to inclement weather, saturated soils,
high groundwater conditions, cover crop harvesting, and site management. The
storage lagoon will be designed to provide effective storage of ninety days of
average daily flow, storage for one foot of minimum pool depth to avoid
vegetation growth, storage for eighteen inches of net (rainfall -evaporation)
rainfall addition, and thirty inches of freeboard. Assuming effective storage
volume is contained within an operating depth of three feet, then total depth will
be eight feet (including freeboard), and total surface area will be about seventy
(70) acres.
73

• Chlorine Disinfection System: Provide a chlorine disinfection system prior to land
application of effluent by spray irrigation. The chlorination system will be
designed to provide thirty minutes of chlorine contact time for the maximum
amount of spray irrigation flow.
• Spray Irrigation Pumps: Provide three (3) spray irrigation pumps, including one
(1) standby. The spray irrigation pumps will be designed for maximum hydraulic
loading rates based upon the water balance and layout of the irrigation fields.
• Spray Irrigation System: Provide header piping and solid -set type spray irrigation
system for land application of effluent. The average hydraulic application rate will
be approximately one inch per week. The area requirement for spray irrigation of
1.1 mgd flow is estimated to be 305 acres. Considering the area required for
effluent storage facilities, buffers, access roads for system management, and
uneconomic remnants, the total area required for land application of effluent is
estimated to be approximately 450 acres.
• Groundwater Monitoring: Provide groundwater monitoring wells for
measurement of groundwater table and sampling of groundwater for compliance
with the water quality parameters included in the non -discharge permit.
• Site Management Equipment Storage and Maintenance Building: Provide a
building for storage of site management equipment and space for maintenance.
• Operation and Control Building: Provide a building for operation staff and
controls.
7.4.4.2 Estimated Project Cost
The total estimated project cost is $21,546,000 in 2007 dollars. See Table 7.7 below for
details. See Figure 7.2 for schematic of this alternative.
74

Table 7.7 - Estimate of Probable Project Cost for Alternative No. 4,
WWTP Expansion to 3.0 mgd, Expanded Discharge to Land Application
UNIT
EXTENDED
NO.
DESCRIPTION
UNITS
QTY
COST
COST
1
New Headworks
LS
1
$525,000
$525,000
2
New Influent Lift Station
LS
1
$440,000
$440,000
3
Anaerobic Tank
LS
1
$515.000
$515,000
4
Splitter Box into Ox. Ditches
LS
1
$35.000
$35,000
5
Ox. Ditch Upgrades
LS
1
$3,000,000
$3,000,000
6
New Clarifier No. 6
LS
1
$445,000
$445,000
7
RAS Pump Upgrade _
LS
1
$65,000
$65.000
8
New Filter Lift Station
LS
1
$485,000
$485,000
9
Chlor / Dechlor Budget (for reuse/emergencies)
LS
1
$55,000
$55,000
10
Sludge Facility Improvements
LS
1
$1,100,000
$1,100,000
11
Admin., Control, & Lab Bldg. Improvements
LS
1
$390,000
$390,000
12
Yard Ppin
LS
1
$245,000
$245,000
13
Electrical (Includes Standby Power)
LS
1
$1,544,000
$1,544.000
14
Misc. Site Work
LS
1
$1,100,000
$1,100,000
15
Secondary Effluent Pump Station
LS
1
$350,000
$350,000
16
16,500 LF of 14 inch Diameter DI Force Main
LS
1
$700,000
$700,000
17
Pavement Replacement
LS
1
_ $5,000
$5,000
18 12-Lane
Bore and Jack w/ Encasement Pipe
LS
1
$14.000
$14,000
19
Creek Directional Bore
LS
1
$47,000
$47,000
20
Air Release Valves
LS
1
$22,000
$22,000
21 J
Effluent Storage Lagoon
LS
1
$1,920,000
$1,920,000
22
Chlorination System
LS
1
$80,000
$80,000
23
Spray Irrigation Pump Station
LS
1
$350,000
$350,000
24
Spray Irrigation System, including Header Piping
LS
1
$1,900,000
$1,900,000
25
Sitework and Piping
LS
1
$400,000
$400,000
26
Site Preparation, Liming, and Seeding _
LS
1
$100,000
$100,000
27
Fencing and Access Roads
LS
1
$300,000
$300.000
28
Monitoring Wells
LS
1
$35,000
$35,000
29
Electrical and Instrumentation
LS
1
$225.000
$225,000
30
Equipment Storage and Maintenance Building
LS
1
$90,000
$90,000
31
Operation and Control Building
LS
1
$90.000
$90,000
Total Construction Cost
$16,572,000
Engineering & Contingency (30%)
$4,974,000
Land Purchase (450 acres) LS 11 $2,000,000
$2.000,000
Total Project Cost
$21,546,000
Note Costs are preliminary an in 2007 dollars. Do not use for construction.
75

7.4.4.3 Estimated Annual Operation and Maintenance Costs
The estimated annual total O&M cost is $980,000 in 2007 dollars. An itemized summary
is shown in Table 7.8 below.
Table 7.8 — Estimated Total Annual O&M Costs for Alternative No. 4,
WWTP Expansion to 3.0 mid, Expanded Discharge to Land Application
ITEM
ANNUAL
Salaries, including fringe benefits:
$280,000
Utilities
Electrical
$315,000
Telephone
$3,000
Chemicals
Lime
$5,000
Alum
$1,900
Polymer
$8,800
Fertilizer
$2,300
Chlorine
$13,000
Maintenance and Repairs
Building
$6,300
Equipment
$50,000
Gas and Lubricants
$16,000
Vehicles
$6,000
Materials
$6,300
Equipment and Safety
$9,000
Contingency
$16,000
Contracted Services:
Skilled Services
$70,000
Sludge Disposal
$100,000
County Landfill Fee
$1,400
Travel and Training:
$3,000
Department Supplies:
$8,000
Permit Fees and Dues:
$2,000
Insurance:
$7,000
Capital Reserve:
$50,000
Total Annual Operation and Maintenance Costs
$980,000
76

7.4.4.4 Estimated Salvage Value
The life of the force main is estimated to be forty years. The useable life of all of the
capital improvements save the force main is estimated to be thirty years. Therefore, using
straight-line depreciation, the salvage value of the improvements at the end of the twenty year
planning period is one-half and one-third of its initial value for the force main and all other
improvements, respectively. From Table 7.7 above, the initial cost of the force main is
$788,000. The initial cost of all other improvements is $15,784,000. Therefore, the salvage
value of the capital improvements is estimated to be $5,655,000 in 2007 dollars.
Land, on the other hand, appreciates in value. Assuming 3 percent compounded growth
in value per year, the value in 2027 is ($2,000,000)(F/P, 3%, 20 years) = $3,610,000.
The total salvage value in 2027 is thus $9,265,000.
7.4.4.5 Estimated Present Worth Cost
The planning period is twenty years. The current USEPA discount rate is 4.875 percent,
compounded annually. The present worth cost is calculated as follows:
Present Worth Cost = $21,546,000 + ($980,000)(P/A, 4.875%, 20 years) —
($9,265,000)(P/F, 4.875%, 20 years) _ $21,546,000 + $12,343,000 - $3,576,000 = $30,313,000
-- $30,300,000.
7.4.5 Alternative No. 5 — Maintain WWTP at 1.9 mgd, Pump Approx. 1.1 mgd Influent to
Harnett County System
Alternative No. 5 would maintain the WWTP at 1.9 mgd and would divert approximately
1.1 mgd of influent to the Harnett County System. (In discussions with Harnett County, 1.0 mgd
is likely the maximum capacity available for sale to Benson.)
This option would require the construction of a headworks facility for screening the
influent, a pumping station to pump the additional flows, and approximately 59,400 LF of force
main to transport the flows to a connection point with the Harnett County System at Turlington.
77

(See Figure 6.1.) In addition, the town would be responsible for capital costs related to the
treatment expansion at the Harnett County WWTP.
7.4.5.1 Estimated Project Cost
The total estimated project cost is $10,040,000 in 2007 dollars. See Table 7.9 below for
details.
Table 7.9 — Estimate of Probable Cost for Alternative No. 5,
Maintain WWTP at 1.9 mgd, Pump Approx. 1.1 mgd Influent to Harnett County System
UNIT
EXTENDED
NO.
DESCRIPTION
UNITS
QTY
COST
COST
1
New Headworks
LS
1
$560,000
$560,000
2
New Influent Lift Station
LS
1
$470,000
$470,000
3
Electrical (Includes Standby Power)
LS
1
$340,000
$340,000
4
Meter at Headworks for Incoming Flow
LS
1
$10,000
$10,000
5
Meter & Vault on New FM on Benson Side
LS
1
$20,000
$20,000
6
Meter & Vault on New FM on Harnett Co. Side
LS
1
$20,000
$20,000
7
Pig Launcher & Retrieval System
LS
1
$8,000
$8,000
8
Odor Control Chemical Feed System
LS
1
$50,000
$50,000
9
12-inch SDR-21 PVC Force Main
LF
59,400
$36
$2,138,400
10
I-95 Crossing (16" HDPE)
LF
600
$200
$120,000
11
I-40 Crossing (16" HDPE)
LF
600
$200
$120,000
12
US-301 Crossing (16" HDPE)
LF
200
$200
$40,000
13
Railroad Crossing North of Benson (12" Bore)
LF
200
$175
$35,000
14
Railroad Crossing North of Turlington (12" Bore)
LF
200
__$175
$35,000
15
Stream Crossings (16" HDPE)
EA
9
$60,000
$540,000
Total Construction Cost
$4,506,400
En ineering & Contingency (30%)
$1,323,600
16
Capital Cost for Treatment Capacity (Paid to Others) 1 LS
1
$4,210,000
$4,210,000
Total Project Cost
$10,040,000
Notes:
1.
Costs are preliminary an in 2007 dollars. Do not use for construction.
2.
Capital Cost for Treatment Capacity based on $4.21/gpd discussed at 9/26/2006 meeting with NCDWQ.
78

7.4.5.2 Estimated Annual Operation and Maintenance Costs
The estimated annual total O&M cost is $758,000 in 2007 dollars. An itemized summary
is shown in Table 7.10 below.
Table 7.10 — Estimated Total Annual O&M Costs for Alternative No. 5,
Maintain WWTP at 1.9 mgd, Pump Approx. 1.1 mgd Influent to Harnett County System
ITEM
ANNUAL
Utilities
Electrical
$40,000
Telephone
$1,000
Chemicals
Odor Control
$100,000
Maintenance and Repairs
Building
$1,000
Equipment
$5,000
Gas and Lubricants
$2,000
Vehicles
$1,000
Materials
$1,000
Equipment and Safety
$5,000
Contingency
$4,000
O&M Charges by Receiving System
Harnett County Wastewater Treatment / Transport Services2
$110,000
Harnett County Transport & Treatment Charges2
$460,000
Travel and Training:
$2,000
Department Supplies:
$3,000
Insurance:
$3,000
Capital Reserve:
$20,000
Total Annual Operation and Maintenance Costs
$758,000
Notes:
1. Costs are preliminary an in 2007 dollars. Do not use for construction.
2. Costs for treatment and transport by others are based on the following discussed at
9/26/2006 meeting with NCDWQ:
Harnett Co. WWTP O&M = $1.25/1,000 gal.
Harnett Co. Transport O&M = $.30/1,000 gal.
79

7.4.5.3 Estimated Salvage Value
The life of the force main and its appurtenances (stream crossings, railroad crossings,
etc...) is estimated to be forty years. The useable life of the capital improvements save the force
main is estimated to be thirty years. Therefore, using straight-line depreciation, the salvage
value of the force main at the end of the twenty year planning period is one-half its value, and the
value of the improvements at the end of the same period is one-third of its initial value. From
Table 7.9 above, the initial cost of the force main is $3,028,400. The initial capital investment
for the other improvements is $5,688,000. Therefore the salvage value in 2027 is $3,410,000 in
2007 dollars.
7.4.5.4 Estimated Present Worth Cost
The planning period is twenty years. The current USEPA discount rate is 4.875 percent,
compounded annually. The present worth cost is calculated as follows:
Present Worth Cost = $10,040,000 + ($758,000)(P/A, 4.875%, 20 years) —
($3,410,000)(P/F, 4.875%, 20 years) = $10,040,000 + $9,547,000 - $1,316,000 = $18,271,000 —>
$18,300,000 .
7.4.6 Alternative No. 6 — Maintain WWTP at 1.9 mgd, Pump Approx. 1.1 mgd Influent to
City of Dunn System
Alternative No. 6 would also maintain the WWTP at 1.9 mgd, but would divert
approximately 1.1 mgd of influent to the City of Dunn System. (For sake of comparison with
Harnett County option, it is assumed that 1.0 mgd would be pumped.) This option would require
the construction of a headworks facility for screening the influent, a pumping station to pump the
additional flows, and approximately 65,500 LF of force main to transport the flows to a
connection point with the City of Dunn System south of US 421. (See Figure 6.1.) In addition,
the town would be responsible for capital costs related to the treatment expansion at the Dunn
WWTP.
80

7.4.6.1 Estimated Project Cost
The total estimated project cost is $10,375,000 in 2007 dollars. See Table 7.11 below for
details.
Table 7.11— Estimate of Probable Cost for Alternative No. 6,
Maintain WWTP at 1.9 mgd, Pump Approx. 1.1 mgd Influent to City of Dunn System
_
UNIT
EXTENDED
NO.
DESCRIPTION
UNITS
QTY
COST
COST
1
New Headworks
LS
1
$560,000
$560,000
2
New Influent Lift Station
LS
1
$470,000
$470,000
3
Electrical (Includes Standby Power)
LS
1
$340,000
$340,000
4
Meter at Headworks for Incoming Flow
LS
1
$10,000
$10,000
5
Meter & Vault on New FM on Benson Side
LS
1
$20,000
$20,000
6
Meter & Vault on New FM on Dunn Side
LS
1
$20,000
$20,000
7
Pig Launcher & Retrieval System
LS
1
$8,000
$8,000
8
Odor Control Chemical Feed System
LS
1
$50,000
$50,000
9
12-inch SDR-21 PVC Force Main
LF
65,500
$36
$2,358,000
10
I-95 Crossing (16" HDPE)
LF
600
$200
$120,000
11
I-40 Crossing (16" HDPE)
LF
600
$200
$120,000
12
US-301 Crossing (16" HDPE)
LF
200
$200
$40,000
13
US-421 Crossing (16" HDPE)
LF
200
$200
$40,000
14
Railroad Crossing North of Benson (12" Bore)
LF
200
$175
$35,000
15
Railroad Crossing West of Dunn (12" Bore)
LF
200
$175
$35,000
16
Stream Crossings (16" HDPE)
EA
9
$60,000
$540,000
Total Construction Cost
$4,766,000
En ineerin & Contingency (30%)
$1,399,000
17
Capital Cost for Treatment Capacity (Paid to Others) I LS I
1
I $4,210,000
$4,210,000
Total Project Cost
$10,375,000
1.
Costs are preliminary an in 2007 dollars. Do not use For construction.
2.
Capital Cost for Treatment Capacity for Dunn are not known at time of report. Costs shown are Harnett County costs and are
based on $4.21/gpd discussed at 9/26/2006 meeting with NCDWQ.
81

7.4.6.2 Estimated Annual Operation and Maintenance Costs
The estimated annual total O&M cost is $763,000 in 2007 dollars. An itemized summary
is shown in Table 7.12 below.
Table 7.12 — Estimated Total Annual O&M Costs for Alternative No. 6,
Maintain WWTP at 1.9 mgd, Pump Approx. 1.1 mgd Influent to City of Dunn System
ITEM
ANNUAL
Utilities
Electrical
$45,000
Telephone
$1,000
Chemicals
Odor Control
$100,000
Maintenance and Repairs
Building
$1,000
Equipment
$5,000
Gas and Lubricants
$2,000
Vehicles
$1,000
Materials
$1,000
Equipment and Safety
$5,000
Contingency
$4,000
O&M Charges by Receiving System
$110,000
Dunn Wastewater Treatment / Transport Services2
Dunn Transport & Treatment Charges2
$460,000
Travel and Training:
$2,000
Department Supplies:
J
$3,000
Insurance:
$3,000
Capital Reserve:
$20,000
Total Annual Operation and Maintenance Costs
$763,000
Notes:
1. Costs are preliminary an in 2007 dollars. Do not use for construction.
2. Costs for treatment and transport by Dunn are not known. Costs listed are Harnett County
costs discussed at 9/26/2006 meeting with NCDWQ:
Harnett Co. WWTP O&M = $1.25/1,000 gal.
Harnett Co. Transport O&M = $.30/1,000 gal.
82

7.4.6.3 Estimated Salvage Value
The life of the force main and its appurtenances (stream crossings, railroad crossings,
etc...) is estimated to be forty years. The useable life of the capital improvements save the force
main is estimated to be thirty years. Therefore, using straight-line depreciation, the salvage
value of the force main at the end of the twenty year planning period is one-half its value, and the
value of the improvements at the end of the same period is one-third of its initial value. From
Table 7.11 above, the initial cost of the force main is $3,288,000. The initial capital investment
for the other improvements is $5,688,000. Therefore the salvage value in 2027 is $3,540,000 in
2007 dollars.
7.4.6.4 Estimated Present Worth Cost
The planning period is twenty years. The current USEPA discount rate is 4.875 percent,
compounded annually. The present worth cost is calculated as follows:
Present Worth Cost = $10,375,000 + ($763,000)(P/A, 4.875%, 20 years) —
($3,540,000)(P/F, 4.875%, 20 years) = $10,375,000 + $9,610,000 - $1,366,000 = $18,619,000 —>
$18,600,000.
83

7.5 Summary of Alternatives and Cost Analyses
below.
A tabular summary of the six alternatives and their costs is presented in Table 7.13
Table 7.13 — Summary of Alternatives and Cost Analyses
Item
Alternatives
Alt. No. 1
Alt. No. 2
Alt. No. 3
Alt. No. 4
Alt. No. 5
Alt. No. 6
WWTP
Expansion
to 3.0 mgd,
Expanded
Discharge to
Hannah
Creek
WWTP
Expansion
to 3.0 mgd,
Expanded
Discharge to
Neuse River
WWTP
Expansion
to 3.0 mgd,
Expanded
Discharge to
Mingo
Swamp
WWTP
Expansion
to 3.0 mgd,
Expanded
Discharge to
Land
Application
Maintain
WWTP at
1.9 mgd,
Pump
Approx. 1.1
mgd
Influent to
Harnett
County
System
Maintain
WWTP at
1.9 mgd,
Pump
Approx. 1.1
mgd
Influent to
City of
Dunn
System
Total Project Cost
$16,345,000
$21,665,000
$18,953,000
$21,546,000
$10,040,000
$10,375,000
Annual O&M Cost
$790,000
$833,000
$825,000
$980,000
$758,000
$763,000
Present Worth
O&M Cost
$9,950 000
$10 492 000
$10 391 000
$12 343 000
' '
$9 547 000
'
$9 610 000
Salvage Value
$4,190,000
$6,129,000
$5,141,000
$9,265,000
$3,410,000
$3,540,000
Present Worth Cost
$24,700,000
$29,800,000
$27,400,000
$30,300,000
$18,300,000
$18,600,000
Note: Costs are preliminary an in 2007 dollars. Do not use for construction.
84

8.0 PROPOSED IMPROVEMENTS
8.1 Description
Based upon the above discussion and analysis of alternatives, the following
recommendations are made for the Town of Benson to pursue:
1. The town should continue to work with the TMDL unit of DWQ to monitor dissolved
oxygen (DO) levels in Hannah Creek. If the data shows that DO levels increase so that
the values are computed to be above the impairment level, the town should work with the
TMDL unit to de -list Hannah Creek. (Note: In North Carolina, DO impairment in Class
`C' waters is triggered when >10.1% of the samples are less than 4 mg/L.) If Hannah
Creek were de -listed, the town would be able to pursue Alternative 1 as described in this
report.
2. The town should seek speculative limits from the state for discharge of the additional 1.1
mgd ADF to either the main stem of the Neuse River or to Mingo Swamp in the South
River Subbasin of the Cape Fear Basin. (It should be noted that according to
conversations with the state, it is unlikely that speculative limits for the discharge into the
Cape Fear Basin would be considered until that basin's model is fully operational.) If
speculative limits are granted for either the Neuse or Mingo Swamp, the town would be
able to pursue either Alternative 2 or Alternative 3 as outlined in this report.
3. The town should continue to be open to potential regional partners for the transport
and/or treatment of the town's wastewater. If a partner can be found and favorable
financing terms can be arranged, the town could pursue alternatives similar to Alternative
5 and Alternative 6 from this report.
4. The town should not consider selling any additional capacity at its WWTP until
provisions are made to either increase the permitted discharge capacity of the plant or
agreements are secured that would allow for the diversion of wastewater from the town to
another regional system for treatment.
5. The town should continue to explore water reuse in the region and be ever -aware of
potential industries or other entities that might serve as significant reuse consumers. As
indicated in the report below, the town currently has one small reuse project in operation
85

with the Johnston County Schools. Preliminary research done as part of this report did
not reveal any other imminent reuse customers in the region.
8.2 Environmental Assessment
The following Environmental Assessment is for the expansion of the treatment and/or
transport systems at the existing WWTP site. In addition — depending on which alternative is
selected — force mains may be constructed off -site to transport either treated or raw wastewater.
8.2.1 Existing Environment
The Benson area has historically centered on agricultural trade, but as transportation
networks have been expanded or constructed, the area has begun to grow. In order to take
advantage of abundant raw materials and migration away from the farm, varied industries have
located near the area. Benson has experienced a slow, but steady population growth. The 2000
census population for Benson was 2,993.
The population of Benson is expected to increase at a more rapid pace as a result of
growth in the Research Triangle Park and Fayetteville areas. The popularity of these regions has
spurred both residential and commercial development and is transforming once small, rural areas
like Benson into mid -size communities. The fastest growth can be seen in those areas with major
transportation routes nearby. Raleigh and Research Triangle Park are accessible from Benson by
Interstate 40, and Fayetteville is accessible by Interstate 95. For these reasons, the Benson
population is expected to grow to about 4,600 by 2025.
The WWTP is located next to Hannah Creek, a tributary to the Neuse River. The
topographic map of the WWTP location is shown in Figure 8.1.
8.2.2 Need for Project
Infrastructure to expand Benson's wastewater handling capacity — either via expansion of
its WWTP or pumped diversion of some of its influent — is needed to comply with state
regulations. The regulations state that when a plant's annual average daily flow reaches eighty
(80) percent of the permitted flow capacity, the system is required to have a plan for an
86

expansion of the wastewater treatment system. When the annual average daily flow at the plant
reaches ninety (90) percent of the permitted flow capacity, the system is required to have plans
and specifications prepared for the plant expansion. As shown in Figure 3.2, it is projected that
the plant will require the 3.0 mgd capacity in year 2020.
In addition, the expansion of Benson's wastewater infrastructure is needed to provide
adequate wastewater treatment needs for the projected residential, commercial and industrial
growth in Benson and Johnston County.
87

Figure 8.1— Topographic Site Map, Town of Benson WWTP
88

8.2.3 Wastewater Treatment Alternatives Analysis
The consideration of an alternative for optimizing performance of the existing facilities is
a required step in any upgrade and expansion. A performance evaluation for the overall
treatment plant and unit operation/processes was provided in Section 4 above. Section 5 details
the anticipated status of the Plant after the implementation of the planned interim improvements
to increase the plant's permitted capacity to 1.9 mgd. Section 6 considers several alternatives
such as: (1) no action, (2) an expansion of the WWTP to 3.0 mgd with expanded discharge to
Hannah Creek, (3) an expansion of the WWTP to 3.0 mgd with expanded discharge to the Neuse
River, (4) an expansion of the WWTP to 3.0 mgd with expanded discharge to Mingo Swamp, (5)
an expansion of the WWTP to 3.0 mgd with expanded discharge to land application, (6)
maintaining the WWTP at 1.9 mgd with approx. 1.1 mgd of influent pumped to Harnett County
System, and (7) maintaining the WWTP at 1.9 mgd with approx. 1.1 mgd of influent pumped to
City of Dunn System.
8.2.4 Existing Environmental Characteristics of Project Area
8.2.4.1 Topography
The topographic features around the Benson WWTP are not great or varied. The plant
has a fairly stable elevation of approximately 150 feet above mean sea level. Effluent from the
plant is discharged into Hannah Creek, a tributary of the Neuse River, which is at an elevation of
140 feet above mean sea level. The plant is not located in the 100-year flood plain.
Flood hazard areas have been identified by the Federal Emergency Management Agency
(FEMA) and are delineated in Flood Insurance Rate Maps. These maps show the location of the
100-year flood hazard area and are provided in Appendix 8.1. While the wastewater plant sits
immediately adjacent to the 100 year flood, none of the current or proposed project area is within
the 100-year flood hazard area.
89

8.2.4.2 Geology and Soils
Underlying Formations: The geological formations of the Benson area consist of two (2)
formations. These underlying geological formations are somewhat overlapping from a
northwesterly to southeasterly lay with a thin layer of the successive formation overlaying the
previous strata on the northwestern edge and becoming thicker towards the southeast.
The Tuscaloosa formation varies in thickness from ten (10) to one hundred (100) feet and
lies above slate formations. Eastward from the Cape Fear River, the Tuscaloosa formation is
probably very deep. Towards the northern and eastern boundaries of the planning area, the
Tuscaloosa formation is overlain by what is known as the Black Creek formation. The Black
Creek formation varies in thickness from only a few feet to as much as one hundred (100) feet or
more within the planning area.
Soils: The soil at the wastewater treatment plant is composed of Gilead sandy loam, two
(2) to eight (8) percent slopes (GeB). GeB is a moderately well -drained soil found in the uplands
on the Coastal Plain. Permeability is moderately slow or slow, and available water capacity is
moderate. A perched water table is a depth of about 1.5 to 2.5 feet during early spring. Surface
runoff is medium. This soil is suited to most urban and recreational uses. Wetness and the slow
permeability in the clayey subsoil are the main limitations. The soil is poorly suited for septic
tank absorption fields.
8.2.4.3 Land Use
Benson is near the Fall Line. It is situated between the highly populous industrial centers
to the north and west, the large agricultural regions to the east in the Coastal Plain, and the Fort
Bragg Military Reservation to the south.
The town is bisected by major transportation facilities. Major highways include
Interstate 95 and US Highway 301 running north and south, and Interstate 40 running east and
west. N.C. Highways 50 and 242 also service the Benson area. The main line of the Seaboard
Coast Line Railroad (now CSX) traverses the planning area running north -south, and a major
branch of the Southern Railway System runs to the north and northwest from the planning area.
Benson, like many other rural towns, developed soon after the Atlantic Coast Line
Railroad (formerly Seaboard and now CSX) was constructed from Smithfield to Fayetteville.
90

The arrangement of existing land uses serving similar functions or having similar characteristics
have generally located near each other. Industries that normally require a good means of
transportation have located on the fringe of the central business district along Interstate 95, US
Highway 301, and the railroad. As with most towns, isolated areas of neighborhood retail and
commercial outlets have developed at random locations through residential areas. Rural areas
surrounding the planning area are used primarily as agricultural and open spaces. Residential
development has generally been confined to strip or small subdivision development along
existing secondary roads.
8.2.4.4 Wetlands
As shown in Figure 8.1 of this PER, the Benson WWTP site is bounded on three (3) sides
by wetlands. According to the Wetlands Online Mapper provided by the U.S. Fish and Wildlife
Service, these wetlands are classified as two (2) different types (see Figure 8.2 below).
DS Flit. L W:W 0.1. S. nmte.Wetlands Online Mapper - Benson WWTP
a su sm aew�atn
UK
❑ cIeBlabs r'—
wi.'
RIP
Ifni.?
flare
In. dm and
1,T.V. -
Ea r.
li
Farm
, Four 009
6 ,,m „„„
®w.
a.r
1.11
El r..am.
— I
4ile1,1.
•
—_. - Map Centre ye• W VLa•'W a'!1 PI her.
Tays naphaarer generated ma*o.tp:t Bonn an lnlernel nnappag •h• and Is 'or general
v h Data layers that ago. VC' thl. map may or may not be aruwale, current
'MI t•Rag ►tj=onfv+%a11ro+t1ea.eo o.etdw.. llj H
Terlyds•+raaa.dee; A' FFD1c- PY_grye fl.F...P.iFOt
M- Scale
p
*Whams* r.6abl. THIS NAP 11 !.OT *O BE USED FOR NAVIGATION
&a1d-leareltA.Aran [lb SeafwalyFaX/6e11C} L1/4
Unavailable (unprojected
data)
Figure 8.2 — Wetlands Online Mapper — Benson WWTP
The wetland to the west and southwest of the project site is a PFO1A class wetland.
According to the U.S. Fish and Wildlife Service, this designation indicates that the wetland is
palustrine, [P], or generally dominated by trees, shrubs, emergents, mosses or lichens. It is
91

considered forested, [FO], so that it is marked by woody vegetation 6 meters (approximately
19.7-feet) in height or taller, and its vegetation is broad-leaved deciduous, [1]. The wetland is
temporarily flooded, [A], meaning surface water is present for brief periods during the growing
season, but the water table usually lies well below the soil surface.
The wetland to the south and east of the site is classified as a PFO1 C wetland. It is
characterized by the same vegetation as the PFO1 A wetland mentioned above. This wetland,
however, is considered seasonally flooded, [C], so that surface water is present for extended
periods, especially early in the growing season, but is absent by the end of the growing season in
most years. The water table after flooding ceases is variable, extending from saturated to the
surface to a water table well below the ground surface.
8.2.4.5 Prime or Unique Agricultural Lands
The wastewater treatment plant is not situated on any prime or unique agricultural lands.
8.2.4.6 Public Lands and Scenic, Recreational, and State Natural Areas
There are no designated parks, scenic or recreational areas, or state natural areas on or
adjacent to the site.
8.2.4.7 Areas of Archaeological or Historical Value
No archaeological sites have been identified on the site of the existing wastewater
treatment plant.
8.2.4.8 Air Quality
At the end of 2004, Johnston County was one of 32 North Carolina counties that were
designated nonattainment for EPA's health -based standards for 8-hour ozone pollution.
8.2.4.9 Noise Levels
The wastewater treatment plant is located in a rural area outside the town of Benson near
the intersection of Interstates 95 and 40. The Plant does not provide a significant source of
noise, particularly in comparison to the nearby interstates.
92

8.2.4.10 Water Resources
Upstream of the plant's effluent discharge into Hannah Creek, the creek merges with two
(2) un-named creeks. The convergence of these creeks forms the boundaries of the wastewater
plant on two (2) sides. Hannah Creek, of the Neuse River System, drains areas north and east
and southeast of the Town of Benson.
Groundwater cannot be classified as plentiful within the Benson area. In the past, the
town used well water as its source of supply. Today, the town is tied to the Water Supply
Systems of the City of Dunn, Harnett County, and Johnston County. The major groundwater
supply source within the planning area is the Tuscaloosa formation, which varies in thickness
from fifty (50) to one hundred (100) feet. This formation can generally produce enough quality
water for rural domestic use with limited process water available.
Due to the porosity of the upper soil layers, shallow wells may become easily
contaminated. The water level in these shallow wells is greatly affected by weather conditions
and renders the wells useless during extremely dry weather. Deeper wells are affected to a lesser
degree by changing weather conditions.
8.2.4.11 Forest Resources
The Division of Forest Resources in Johnston County reports that no municipality owns
forested timberland.
8.2.4.12 Wildlife and Natural Vegetation
There are seventeen (17) species of flora and fauna in Johnston County that are classified
by the U.S. Fish and Wildlife Service as endangered or as species of federal concern. While
their presence is of significant concern, the locations of habitats of these ecological resources are
not specifically delineated. The endangered, threatened, and rare species in Johnston County are
listed in Table 8.1.
93

Table 8.1 — Endangered, Threatened, and Rare Species in Johnston County
Scientific Name
Common Name
Status
Vertebrates
Noturus furiosuspopulation 1
"Neuse" madtom
FSC
Lythruurus Matutinus
Pinewood Shiner
FSC
Picoides Borealis
Red -Cockaded
Woodpecker
E
Invertebrates
Lasmigona subviridis
Green Floater
FSC
Elliptio Lanceolata
Yellow Lance
FSC
Elliptio Steinstansana
Tar Spiny Mussel
E
Fusconaia Masoni
Atlantic Pigtoe
FSC
Lampsilis Cariosa
Yellow Lampmussel
FSC
Alasmidonta heterodon
Dwarf wedge mussel
E
Procambarus medialis
Tar River Crayfish
FSC
Vascular Plants
Lilium iridollae
Sandhills bog lily
FSC
Tofieldia glabra
Carolina asphodel
FSC*
Macbridea caroliniana
Carolina bogmint
FSC
Ludwigia brevipes
Long beach seedbox
FSC*
Rhus michauxii
Michaux's sumac
E*
Solidago verna
Spring -flowering
goldenrod
FSC
Trillium Pusillum Var
Pusillum
Carolina Least Trillium
FSC
FSC = Federal Species of Concern E =
Endangered
*The species was last observed in the county more than 50 years ago.
8.2.5 Environmental Consequences
Few environmental consequences are expected as a result of construction of the proposed
improvements. Any consequences from treatment plant construction are expected to be minimal
and temporary. These facilities will be built on the site of the existing wastewater treatment
plant on previously disturbed land.
Force mains would be built as much as possible in NCDOT rights -of -way. It is
anticipated that stream crossing would be performed using directional drilling techniques to
minimize environmental disturbance.
94

8.2.5.1 Topography
No major grading or topography changes are anticipated as part of the treatment plant
expansion. Necessary excavation will be backfilled as much as possible with native material.
The work will not permanently alter the topography of the land or encroach on any flood plains.
8.2.5.2 Soils
As much as possible, native soil will be used to backfill all trenches and excavations.
Borrow material is expected to be minimal, and any borrow brought on -site will have to meet
specifications for suitability. If necessary, the project's contractor will be required to transport
excess excavated material offsite for reuse or disposal in accordance with applicable regulations.
It is not expected that the soil in the area will dramatically change, and there is no reason to
suspect that the soil would be contaminated during construction.
8.2.5.3 Changes in Land Use
Land use changes are not expected with the construction of additional wastewater
treatment units. Construction of additional treatment units will occur on the previously disturbed
site of the existing wastewater treatment plant.
To minimize force main lengths, the town might consider purchasing easements where
doing so would provide a more direct pipeline route and thereby minimize the amount of
disturbance.
8.2.5.4 Wetlands
No primary or indirect impacts on wetland areas are expected as a consequence of
expanding the wastewater treatment plant on the existing site. At stream crossings or wetlands,
force mains would be installed using directional drilling or other trenchless techniques.
8.2.5.5 Prime or Unique Agricultural Lands
No primary impacts on prime or unique agricultural lands are expected as a consequence
of expanding the wastewater treatment plant. The additional treatment units will be constructed
on the existing site of the wastewater treatment plant on previously disturbed land owned by the
town.
95

8.2.5.6 Public Lands
There are no public lands located on the wastewater treatment plant site that are to be
disturbed by construction of the project.
8.2.5.7 Scenic or Recreational Areas
The project will have no adverse effects on scenic and recreational areas.
8.2.5.8 Areas of Archaeological or Historical Value
No archaeological sites have been identified on the site of the existing wastewater
treatment plant. The National Register of Historic Places in Johnston County does not list
anything in the Town of Benson.
8.2.5.9 Air Quality
The construction of the proposed facilities will have a short term impact on the air quality
as construction equipment and other construction -related traffic increases the pollutant levels in
the area. There may be a temporary increase in particulate matter in the air surrounding the
construction, but the project will not have any permanent impact on air quality.
Increasing the capacity of the wastewater treatment plant allows for development of the
Benson area, which could increase the traffic volume and consequently increase the
concentration of pollutants such as nitrogen dioxide, sulfur dioxide, etc. in the ambient air.
Because of the open nature of the area and present quality of the local atmosphere, it is
anticipated that there will be minimal adverse secondary impacts on air quality from increased
development in the area.
8.2.5.10 Noise Levels
Noise levels may increase during the construction of the proposed facilities, but their
impact will be temporary and during daylight hours only. Noise levels are expected to return to
normal when construction of the project is completed. A secondary adverse impact on the
96

atmosphere could be increased noise resulting from development in the area. Traffic -related
noise increases with population growth.
8.2.5.11 Water Resources
Primary impacts on the quality of the groundwater are expected to be minimal or none.
The project will cause a minimal increase in impermeable surface coverage at the wastewater
treatment plant, but should not affect the groundwater recharge rates. Also, no primary or
secondary impacts on the drinking water supplies will occur as a result of the project.
A secondary adverse impact from this project is the possibility of decreased water quality
due to additional runoff from increased urbanization. Urban runoff is comprised of soluble and
suspended matter, including, but not limited to, degradation of asphaltic and concrete pavements,
various contributions from motor vehicles, fallout from the atmosphere, vegetation, litter, spills,
and other sources. Constituents of urban runoff may lower the dissolved oxygen content of
receiving waters as well as add high concentrations of heavy metals that might inhibit biological
activity in receiving streams.
The Neuse River is a nutrient sensitive water, which means the state is sensitive to both
point and nonpoint sources of nitrogen delivered to the river. There is a potential for adverse
impacts on the quality of surface waters if the project's contractor does not properly protect the
areas from storm water runoff of disturbed areas. However, the project's contractor will be
required to use approved sedimentation and erosion control measures to provide safeguards.
Where needed, silt fencing will be required. Disturbed areas will be stabilized as soon as
practical with mesh matting, seeding, and mulching. Rock check dams and temporary sediment
traps will be utilized as needed to capture any temporary silting.
Increased eutrophication of receiving waters is not expected from the implementation of
the project. The proposed wastewater treatment facility's expansion will not hinder the WWTP's
ability to remove nitrogen and phosphorus prior to discharge to Hannah Creek and the Neuse
River.
8.2.5.12 Forest Resources
Forest resources will not be affected by the wastewater plant improvements because no
additional clearing will be required. The plant expansion will not result in the conversion of any
97

forested lands as additional treatment units will be constructed on the existing site of the
wastewater treatment plant, which is previously disturbed land owned by the town.
8.2.5.13 Shellfish or Fish and their Habitats
No shellfish or fish and their habitats are expected to be affected by the proposed project.
The project's contractor will be required to protect receiving waters from storm water runoff
from the disturbed areas. The proposed design will use various sedimentation and erosion
control measures to provide safeguards. Silt fence, mesh matting, seeding, and mulching will be
required where necessary to control runoff and reestablish areas during construction or as soon as
practical after construction. In addition, rock check dams and temporary sediment traps will be
required where necessary to capture any temporary silting. With the proper use of these
measures, it is not expected that the project will have an adverse impact on shellfish or fish and
their habitats.
8.2.5.14 Wildlife and their Habitats
It is not anticipated that construction activities will have an effect on wildlife or their
habitats. All construction at the wastewater treatment plant will take place on previously
disturbed land. No additional clearing will be required for the project; therefore, the vegetation
in the project area is not expected to be destroyed or altered. Additionally, there should be no
displacement of wildlife as their habitats are not expected to be damaged.
8.2.5.15 Introduction of Toxic Substances
It is not anticipated that toxic substances will be introduced to the environment as a result
of the proposed project.
98

8.2.6 Mitigative Measures
8.2.6.1 Water Resources
Proper sedimentation and erosion control techniques will be required to protect water
quality. An erosion and sedimentation control plan will be made part of the plans and
specifications for all wastewater treatment plant upgrades. The contractor will be required to
follow these designs in order to mitigate erosion and sediment transport. Silt fence, mesh
matting, seeding, and mulching will be required where necessary to control runoff and
reestablish areas during construction or as soon as practical after construction.
Stream or wetlands crossings of force mains would be installed using trenchless
installation techniques such as directional drilling.
8.2.6.2 Noise Levels
Noise during construction can be minimized by operating equipment during daylight
hours and maintaining muffler systems on all the machinery used in construction.
8.2.7 References
Johnston County Endangered Species. Threatened Species, and Federal Species of Concern, U.S.
Fish and Wildlife Service, 2003.
Johnston County, North Carolina, National Register of Historic Places, 2002.
N.C. Floodplain Mapping Information System, On -Line Mapping Application.
Neuse River Basin Nutrient Sensitive Waters Management Strategy, North Carolina Nonpoint
Source Management Program, North Carolina Department of Environment and Natural
Resources, 1998.
8.2.8 State and Federal Permits Required
Expanding the discharge to 3.0 mgd at the Benson WWTP would require a revised
NPDES Permit from the NC Department of Environment and Natural Resources, the Division of
99

Water Quality (DWQ). As noted above, an expanded permit for Hannah Creek is unlikely at this
time. A permit may be issued to discharge the additional effluent directly to the Neuse. It is
recommended that the town seek speculative limits for 1.1 mgd to the Neuse and Mingo Swamp.
(According to meetings held with DWQ, a permit to discharge to Mingo Swamp may also be
unlikely.)
The project will also require an erosion control permit. This permit must be obtained
before any construction begins.
8.3 Implementation
8.3.1 Institutional Responsibilities
The Town of Benson has the legal authority and financial capability to construct and
operate the proposed wastewater treatment improvements.
In order to construct force mains, the town would need to enter into encroachment
agreements with the North Carolina Department of Transportation (NCDOT) for any pipes or
appurtenances installed within NCDOT rights -of -way.
8.4 Financing
8.4.1 Potential Sources
Over the past three decades, the State of North Carolina has established several programs
and funding sources to assist in financing the ever-increasing need for new, upgraded, or
expanded infrastructure. Simultaneously, the federal government has underwritten the financing
of water and sewer facilities as well. Grant programs were abundant during the 1970s and early
1980s; however, federal sources have waned and the states have had to take on a more
responsive role in meeting infrastructure funding needs.
Today, several funding sources still remain with favorable loan programs taking the place
of the once -plentiful grant programs. Usually, the optimum funding package includes a small
grant, with the remaining monies coming from a loan. Not too surprisingly, loan programs differ
100

both in interest rate and term, which force the local government applicant to evaluate the various
options.
Benson's median household income level prevents it from being eligible for a USDA
Rural Development grant, which could range as high as one million dollars. However, the town
remains eligible for a Rural Center Supplemental Grant. And if there arises an opportunity
whereby an industry chooses to locate within the town's service area and create new jobs, there
is the potential to receive an economic development grant from either (and possibly both) the
Rural Center or the Department of Commerce.
In addition, over the past two years, the N.C. General Assembly has been considering a
strategy to provide a more consistent stream of grant funds for local governments in financial
need. A new funding plan may be introduced and adopted by the legislature during the 2007
session.
The town's strategy with regards to grant funding should be to monitor its availability
and determine the most favorable conditions under which to apply.
Loan financing is always available, yet the terms and conditions vary and require careful
consideration based upon existing economic conditions. When a local government is
experiencing positive growth and a capital project can be developed or "phased" over several
construction periods, short term loans would seem like a worthwhile approach. Where growth is
not as pronounced, it may be best to select a loan program over a more extended period in order
to maintain user charges within a range that minimizes the impact on the resident customer base.
Economic conditions relative to Benson's long range wastewater treatment needs are
such that a long term loan coupled with an optimum grant may be the recommended strategy.
While the town has been able to expand the plant in increments over the past 25 years, it appears
that the next expansion will need to go all the way from 1.9 mgd to 3.0 mgd. In the meantime,
growth should be monitored to determine the "spill over" effect from western Johnston County.
Completion of the southern arc of the 1-540 "outer loop" in Wake County will also impact
101

development and growth patterns as residents of the Benson service area will be able to enjoy
shorter commutes to the Research Triangle Park and North Raleigh areas of employment.
Because of the magnitude of the next expansion, the town should pursue grant
opportunities and long term loan financing. Grant funds will most likely come from a state -
approved program. For loans, however, the town will likely have the choice of a USDA -Rural
Development loan (40 years @ 4.5%) or a state low -interest loan (20 years @ 2.5%). A shorter
term loan (less than 20 years) is probably not affordable unless a means is devised to phase the
construction.
8.4.2 User Charges
While it is essentially an academic exercise to project a user charge that may not go into
effect for another 12 to 15 years, it is worthwhile to acknowledge the potential impact in terms of
today's construction costs. Changes in the standard of living and the economy are open for
speculation; however, a not -too -unreasonable projection of sewer user charges is provided with
the following example:
• Projected Project Cost: $16,345,000
• Optimum Grant Package(s): $ 2,500,000
• Low Interest Loan: 20 years @ 2.5%
• Customer Base Demand at Expansion: 1.5 mgd
Given the basic information cited above, a projected increase in user charges can be
calculated:
• Annual Debt Service: 13,845,000 x 0.0642 = $888,849/yr
• Annual Sewer "Sales": 1.5 mgd x 365 days/yr = 547.5 mg/yr
• Unit Cost for Wastewater Treatment: $888,849/yr +547.5 mg/yr = $1.62/1000 gal
102

At the time of the expansion, the town will likely be completing payment on the loan for
the WWTP expansion to 1.9 mgd. Therefore, debt retirement will likely offset a portion
(perhaps 25%) of this projected increase in user charges. However, with the current overall cost
of treatment being in the range of $2.25 per 1000 gallons, one can anticipate the next major
expansion may increase rates by 50% or more. Many communities are currently experiencing
user charges in the range of $4.00/1000 gal; however, comparisons are of little consolation to a
community such as Benson, where utility rates have traditionally been quite competitive.
The benefit of this exercise simply provides a view of the future, which in turn will help
local government officials see the benefit of monitoring financing opportunities and considering
alternative means to finance the growth that will impact Benson over the next decade.
103

Appendix 2.1— NPDES Permit No. NC0020389

- , 4,
January 20, 2006
Mr. Keith Langdon, Town Manager
Town of Benson
P.O. Box 69
Benson, North Carolina 27504
Subject:
Dear Mr. Langdon:
The Division sent the draft NPDES permit NC0020389 modification to public notice on November 23, 2005
and the public notice comment period has now ended
Michael F. Easley, Governor
State of North Carolina
William
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
NPDES Permit Modification
Permit Number NC0020389
Town of Benson WWTP
Johnston County
In accordance with your permit modification request and our review, the Division is forwarding herewith a
modification to the subject perrnit. Enclosed please find the modified permit. This permit modification is issued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the U. S. Environmental Protection Agency dated May 9, 1994 (or as subsequently
amended).
If any parts, measurement frequencies or sampling requirements contained in this
you, you have the right to an adjudicatory hearing upon written request within t 3 permitfoareow unacceptablereceiptoto
letter. This request must be in the form of a written petition,othirty 1 0) days following of this
of the North Carolina
General Statutes, and filed with the Office of AdministrativHearings conforming671 Mail Servicapter e Center, Raleigh, North
Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may require
modification or revocation and reissuance of the permit. This permit does not affect the legal re
other permits which may be required by the Division of Water Quality or g requirements to obtain
Resources, the Coastal Area Management Act or any other Federal or Local g i n bye the Division of Land
required. permit that may be
If you have any questions concerning this permit, please contact Mrs. Dawn Jeffries at telephone number
[phone], extension 595.
Sincerely,
Enclosure: Permit Modification
cc: Raleigh Regional Office, Surface Water Protection Section
Aquatic Toxicology Unit
NPDES Files
EPA Region 4
The Wooten Company Y c a1'1601(.5
120 N. Boylan Avenue
Raleigh, NC 27603
Attn: Vance Brooks, P.E.
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-161 7 - TELEPHONE [phone]/FAX [phone]
VISIT US ON THE WEB AT http://h2o.enr.state.nc.us/NPDFS

Permit NC002038c
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Water Quality
Commission, and the Federal Water Pollution Control Act, as amended, the
Town of Benson
is hereby authorized to discharge wastewater from a facility located at the
Benson Wastewater Treatment Facility
770 Hannah Creek Road (south of I-95)
Four Oaks
Johnston County
to receiving waters designated as Hannah Creek in the Neuse River Basin in accordance
discharge limitations, monitoring requirements, and other conditions set forth in Parts I, II, III e
and IV hereof.
This permit shall become effective March 1, 2006.
This permit and authorization to discharge shall expire at midnight on April 30, 2008.
Signed this day January 20, 2006.
-Cr 1 Alan W. ' imek, P.E., i3' ector
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC002038c
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked.
As of this permit issuance, any previously issued permit bearing this number is no banger effective.
Therefore, the exclusive authority to operate and discharge from this facility
conditions, requirements, terms, and provisions included �s es under the permit
The Town of Benson is hereby authorized to:
1. Continue to operate an existing 1.5 MGD wastewater treatment facility consisting of
the following components:
• Bar screen
• Grit removal
• Parshall flume with flow measurement
• Influent screw pumps
• Three extended aeration/oxidation basins
• Four secondary clarifiers
• Tertiary filters
• Chlorine contact basin
• Dechlorination -
• Post aeration
• Alum and lime storage/handling units,
• Aerated sludge lagoon
• Two stabilization lagoons (also act as influent flow storage)
• Lagoon effluent return. pump station; and
This facility is located at the Benson WWTF off Hannah Creek Road in Four Oaks, Johnston
County.
2. Upon receiving an Authorization to Construct from the Division of Water Quali
construct and operate a 1.9 MGD wastewater treatment system. ty'
3. Operate facilities for reuse water of up to 0.02324 MGD in accordance with Non -
Discharge permit number WQ0022501.
4. Discharge wastewater from said treatment works at the location specified on the
attached map into Hannah Creek, classified C-NSW waters in Neuse River Basin.

Latitude: 35°23'21"
Longitude: 78°30'29"
Quad #: F24NE
Receiving Stream: Hannah Creek
Stream Class: C-NSW
Subbasin: 30404
NC0020389
Town of Benson
WWTP
Facility
Location
ISCALE 1:211000

A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
NC0020389
During the period beginning on the effective date of the permit and lasting until expansion above 1.5 MGD,
the Permittee is authorized to discharge 1.5 MGD of municipal wastewater from outfali 001. Such
discharges shall be limited and monitored by the Permittee as specified below:
EFF�1, "' y.;•E ;I R
A • t'!'MR� 1
p, "I
I_� '.1,µ
riq
Flow 1.5 MGD
Total Monthly Flow (MG)
Monitor and Report
BOD, 5 day (200C)2 [Apr111-October 31] 5.0 mg/I
BOD, 5 day (200C)1 [November 1-March 10.0 mg/I
31]
Total Suspended Solids=
30.0 mg/I
7.5 mg/I
15.0 mg/I
45.0 mg/I
NH) as N [April 1- October 31) 2.0 mg/I 6.0 mg/i
LNH3 as N [November 1- March 31] 4.0 mg/I 12.0 mg/I
Dissolved Oxygen3
Dissolved Oxygen
Fecal Collform (geometric mean)
Fecal Coliform (geometric mean)
Total Residual Chlorine
TKN (mg/L)4
NO2 + NO3 (mg/L)'
Total Nitrogen(mg/1.)`
Total Nitrogen Loads
Total Phosphorus°
Temperature (0C)
Temperature (0C)
Sonducttvity
Conductivity
Chrtxtic Toxicity,
Total Chromium
Total Nldcel
Total Mercury
Total Copper
200/100 ml
400/1.00 mi
17 µg/L
Monitor and Report
Monitor and Report
Monitor and Report
Monitor and Report (pounds/month) -
33,790 pounds/year
2.0 mg/L (Quarterly Average)
501ig/I
138 J.L9/1
1,022 µg/1
261 ug(I
Continuous Recording
Monthly Recorded or
Calculated
Daily Composite
Daily Composite
Daily Composite
Daily Composite
Daily _ Composite
Daily Grab
Variable'
Grab
Daily Grab
Variable1 Grab
Daffy Grab
Weekly Composite
Weekly Composite
Weekly Composite
Monthly Calculated
Annually Calculated
Weekly Composite
Daily Grab
Variables
Daily
Variable1 .
Quarterly
Weekly
Weekly
0.012 ug/I ( Weekly
2/Month
Grab 1
Influent or
Effluent
Effluent
Influent &
Effluent
Influent &
Effluent
Influent &
Effluent
Effluent
Effluent
Effluent
U& D
Effluent
U& D
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Grab U& D.
Grab
Composite
Composite
Composite
Grab
Composite
Effluent
U& D
Effluent
Effluent
Effluent
Effluent
Total zinc 2/Month
PM 6.0-9.0 standard units Daily
Footnotes:
1. U: Upstream rt the culvert on NCSR 1158. D: Downstream at (1) NCSR 1227 and (2) I-95 culvert. Stream samples shall be grab
samples collected 3/Week from June to September and 1 /Week during the remaining months of the year. Instream monitoring
is provisionally waived in light of the Permittee's participation in the Lower Neuse Basin Association. Iastream
monitoring shall be conducted as stated in this permit siaould the Permittee end its participation in the Association.
2. The monthly average effluent SODS and Total Suspended Solids concentrations shall not exceed 15% of the respective influent
retnov
The daily avenge dissolved oxygen effluent concentration nothe7ess tliiart 6Irri t.
Composite
Grab
Effluent
Effluent
Effluent
For a given wastewater sample, Total Nitrogen = TKN + NO3-N + NO2-N where TEN is Total K1eldah1 Nitrogen, and NO3-N
and NOz-N are Nitrate and Nitrite Nitrogen, respectively.
5. Total Nitrogen Load is the mass quantity of Total Nitrogen discharged in a given period of time. See A. (4). The annual TN Load
limit shall become effective with the calendar year beginning on January 1, 2003. Compliance with this limit shall be determined in
accordance with condition A. (5), Annual limits for Total Nitrogen.
6. The quarterly average for total phosphorus shall be the average of composite samples collected weekly during the calendar quarter
(January -March, April June, July -September, October -December).
7. Chronic Toxicity (Ccriadaph,ria dubia) P/F at 90°/a: January, April, July, and October [see condition A. (3)]. Toxicity monitoring shall
coincide with metals monitoring.
There shall be no discharge of floating solids or visible foam in other than trace arnoiiritQ

A. (2.) EFFLUENT LIMITATIONS AND Permit NC0020389
ginning after
During the period be MONITQRING REQUIREMENTS
above 1.5 MGD and lasting until expiration, the Permit
authorized to discharge 1.9 MGD of municipal wastewater from outfall ❑01,
limited and monitored by the Perrnittee as specified below: tee is
Such discharges shad be
EFF1; ti f
CH JARA
Flow
Total Monthly Flow (MG)
BOD, 5 day (20°C)' [Apt 1-October 31]
BOD, 5 day (20°C) [November 1-March
31
Total Suspended Solids=
NH as N 'rII 1- October 31
NH as N November 1- March 31
Dissolved n
As -
Dissolved Oxygen
Fecal Coilfarm •eometric mean
Fecal Coliform (geometric mean)
Total Residual Chlorlhe
TKN
N
•
N
Total NI
.. R
m• L
en
Total Nitro9en Loads
Total Plios.harus
Te- �h+re °C
Temperature (°C)
Cond
Conductivity
Chronk Tax
Total Chromium
Total Nickel
Total Mercu
Total .,. -r
Total Zinc
Monthly
Recording
Recorded or
Calculated
Composite
x �y �
Vf Ji�l� 0 '� ':slid I L $ l`r
oiiti'' �: • ...•.. �.. w
■F-YFC'1M - 1 1
�4YRrga tK .' ' .9ra' a r�l
1.9 MGD
Monitor and Report
5.0 mg/I 7.5 mg/I
10.0 mg/I 15.0 mg/1
30.0 mg/I 45.0 mg/I
1.0 m
2.0 m • I
200 100 mi
Monitor and Repot
Monitor and Report
Monitor and Re
50
88
call . n
Influent or
Effluent
Effluent
Influent &
Effluent
Influent &
Effluent
Influent &
Effluent
Effluent
Effluent
Effluent
U& D
Effluent
U& D
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
U& D
Effluent
U& D
Effluent
Effluent
Effluent
Effluent
�"�' • • Effluent
Month Corn. • to 6.0 - 9.0 standard unit fluent
Footnotes: 6.0
Grab Effluent
1. U: Upstream at the culvert on NCSR 1158. D: Downstream at (1) NCSR 1227 and
samples collected 3/Week from June to September and 1/Week during I-n t s ofti ns� stall it grog
is samples
oflc w the remaining
fly waived in light of the Pernxittes's participation in the Lower Neuse Basin Association. Instream
monitoring shag be conducted as stated in this permit should the months the year. Instream monitoring
2. The month] avers end itsparticipation
Y ge efflucrct $OD5 and Total Suspended Residue conccrttrateons stall nott exceed 15 % o f the respective tt influent
value monthly
removal).
3. The daily average dissolved ox
ygen effluent Concenttatian shall not be less than 6.0 mg/1.
`1• For a giverx wastewater sample, Total Nitres _ __ ._,__.... _ . -.-----_.. -- _ • -- _ - _ _-- — -- - --- and NO2--N are Nitrate and Nitrite Nitrogen,rresprec NO3-N + NO2--N where I is Total Kjcldahl Nitrogen, y.
5. Total Nitrogen Load is the mass quantity ol-Total Nitrogen discharged in a given $�' and NO3-N
limit shall become effective with the calendar year beginning o � period of time. See A. [4}. The annual TN Load
accordance with condition A. for l Nitrogen.
on 1, 2003. Compliance with this limit shall be determined in
6. The quarterly average for total pho�sp ❑rusT Limits
he the average composite Barn les c
ganuary-March, April June, July -September, October -December). p ❑�eCted weekly du> g the calendar quarter
7. Chronic Toxicity (Cerradaphnia dubia) ID/Fat 90%: January, April, July, and October [see condition A. 3 . To
coincide with metals monitoring. [ )] Toxicity monitoring shall
There shall be no discharge of floating solids or visible foam in other than trace amnii to

A. (3) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or
significant mortality to Ceriodaphnia dubia at an effluent concentration of 90%.
The permit holder shall perform at a minimum, quarterly monitoiing using test procedures
outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised
February 1998, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent
Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be
performed during the months of January, April, July and October. Effluent sampling for this
testing shall be performed at the NPDES permitted final effluent discharge below all treatment
processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV
below the permit limit, then multiple -concentration testing shall be performed at a minimum, in
each of the two following months as described in "North Carolina Phase II Chronic Whole
Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean
of the highest concentration having no detectable impairment of :reproduction or survival and
the lowest concentration that does have a detectable impairment of reproduction or survival. The
definition of "detectable impairment," collection methods, exposure regimes, and further
statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity
Test Procedure* (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the
Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed, using
the parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value.
Additionally, DWQ Form AT-3 (original) is to be sent to the following address:
NC DENR / DWQ / Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch
•
no later than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements
and all concentration/response data, and be certified by laboratory supervisor and ORC or
approved designate signature. Total residual chlorine of the effluent toxicity sample must be
measured and reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity
monitoring is required, the Permittee will complete the information located at the top of the
aquatic toxicity (AT) test force indicating the facility name, permit number, pipe number, county,
and the month/year of the report with the notation of No Flow" in the comment area of the
form. The report shall be submitted to the Environmental Sciences Branch at the address cited
above.
Permit NC0020389
Should the Permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Water Quality indicate potential impacts to the receiving stream, this permit may be -
re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls, shall
constitute an invalid test and will require immediate follow-up testing to be completed no later than the
last day of the month following the month of the initial monitoring.

A. (4) CALCULATION OF TOTAL NITROGEN LOADS Permit NC0020389
a. The Permittee shall calculate monthly and annual TN Loads as follows:
i. Monthly TN Load (pounds/month) = TN x TMF x 8.34
where:
TN = the average Total Nitrogen concentration (mg/L) of the composite samples collected during the month
TMF = the Total Monthly Flow of wastewater discharged during the month (MG/month)
8.34 = conversion factor, from (rrmglL x MG) to pounds
if. Annual TN Load (pounds/year) = Sum of the 12 Monthly TN Loads for the
calendar year
b. The Permittee shall report monthly Total Nitrogen results (mg/L and pounds/month)
in the discharge monitoring report for that month and shall report each year's
annual results (pounds/year) in the December report for that year.
A. (5) ANNUAL LIMITS FOR TOTAL NITROGEN
a. Total Nitrogen (TN) allocations and TN Load limits for NPDES dischargers in the
NeuSe River basin are annual limits and are applied for the calendar year.
b. For any given calendar year, the Permittee shall be in compliance with the annual TN
Load limit in this Permit if:
i. the Permittee's annual TN Load is less than or equal to said limit, or
ii. the Permittee is a Co-Permittee Member of a compliance association.
c. The TN Load limit in this Permit (if any) may be modified as the result of allowable
changes in the Permittee's TN allocation.
i. Allowable changes include those resulting from purchase of TN allocation from
the Wetlands Restoration Fund; purchase, sale, trade, or lease of allocation
between the Permittee and other dischargers; regionalization; and other
transactions approved by the Division.
ii. The Permittee may request a modification of the TN Load limit in this Permit to
reflect allowable changes in its TN allocation. Upon receipt of timely and proper
application, the Division will modify the permit as appropriate and in accordance
with state and federal program requirements.
iii. Changes in TN limits become effective on January 1 of the year following permit
modification. The Division must receive application no later than August 31 for
changes proposed for the following calendar year.
iv. Application shall be sent to:
NCDWQ / NPDES Unit
Attn: Meuse River Basin Coordinator
Mail Service Center
Raleigh, NC 27699-1617
d. If the Permittee is a member and co-Permittee of an approved compliance
association, its TN discharge during that year is governed by that association's group
NPDES permit and the TN limits therein.
i. The Permittee shall be considered a Co-Permittee Member for any given calendar
year in which it is identified as such in Appendix A of the association's group
NPDES permit_
ii. Association roster(s) and members' TN allocations will be updated annually and
in accordance with state and federal program requirements.

P
NC
iii. If the Permittee intends to join or leave a compliance associations hetDiviO on038�
must be notified of the proposed action in accordance with the procedures
defined in the association's NPDES permit.
(1) Upon receipt of timely and proper notification, the Division will modify the
permit as appropriate and in accordance with state and federal program
requirements.
(2) Membership changes in a compliance association become effective on January
1 of the year following modification of the association's permit.
The TN monitoring and reporting requirements in this Permit remain in effect until expiration of
this Permit and are not affected by the Permittee's membership in a compliance association.
A. (6) LAGOON FREEBOARD HEIGHT REQUIREMENT .
A minimum of 2 feet of freeboard height must be maintained in the lagoons (currently used for
equalization/sludge holding). A staff gauge must be placed in each lagoon and the height
recorded daily.

A. (7) EFFLUENT POLLUTANT SCAN
The Permittee shall perform an annual Effluent Pollutant Scan for all parameters listed in the attached table. The
analytical methods shall be in accordance with 40 CFR Part 136 and shall be sufficiently sensitive to
determine whether parameters are present in concentrations greater than applicable standards and
criteria. Samples shall represent seasonal variations. Unless otherwise indicated, metals shall be
analyzed as "total recoverable."
Ammonia (as N)
Permit NC0020389
Chlorine (total residual, TRC)
Dissolved oxygen
Nitrate litrite
Kjeldahl nitrogen
oil and grease
Phosphorus
Trans-1,2-dichloroethy lens 8Es (2- hloroethyl) ether
1,1 •dkhiomethylene Bfs (2t,hkroisopropyi) ether
1,2-dk ioroprnpane els (2-ethylhexyl) phthalate
1.3-dlohloropnopylene 4•br nophenyt phenyl ether
Ethylbenzene Butyl benzyl phthalate
Methyl bromide 2-chloronaphMariana
Total dlssolved solids
Hardness
Antimony
Arsenic
Betybum
Cadmium -
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Siker
Tha5um
Zinc
Cyankla
Maki chloride 4-chlomphenyl phenyl ether
Methylene chloride Chrysene
1,1,22-tetrachbroethane Di-nbutyl phthalate
Tetrachlorcethylene Di-n-octyi phthalate
Toluene
1,1,1-bichioroethane
O ben zo(a,h)anthrecene
Total phenolic compounds
Volatile organic compounds.:
Akrdein
Acrylorrtree
Benzene
Bromobrm
12-0fchiorobenxene
1,1,2.b1chbroethane 1,3-dichlorobenzene
Tddronoethyiene 1,4 hiorobenzane
Vinyl chloride 3,3-dddtbrnberuidine
Acid-e,drectable compounds Diethyl phthalate
P-chloro-m.cresa _ D nelhyl phthalate
2 dlbmphenoi 2,4-dinttra401iens
2,4-dichlorophena 2,6-dinitrolokaene
2,4- imelhyiphenol 1.2-rilpher+yihydraxine
4,6-dinitro-o-cresol Fkroranl}rena
2,4-dkiitrophenol F#rorene
2-nitmpherror Hekaddarobenxene
4-nrtrophend Hexachiornbutadiene
Pentachlorophenol Hexachloracydo.pentadiene
Phenol
Carbon tekadioride
Chlorobenxrne
Chbrodlbrornomethane
Chloroethane
Herachlaroethane
2,4,13-kichlornphend lrxleno(1,2,3-cd)pyrene
Bose -neutral compouncON Isophcgone
Acenaphthene Naphthalene
Acenaphthylene Nitrobenzene
Antlraoene
Benzidtrre
2-chloroelhyktnyl ether
Chloroform
Dlchlorobrkmiomethane
1,1 -dichloroethane
1,2dlchloroethane
Benzo(a)anthracene
N nikvsodi-n-propylamine
N-nkrwodimethylamine
N rosadiphenyiemine
Berao(a)pyrene Phenenthrene
3,4 benzotluor-anthene
Pytene
Benzo(ghl)perylene 1,2,4-trichk robenzene
Benm(k)ibaranthene
Bls (2-chlaroethoxy) methane
Test results shall be reported to the Division in DWQ Form- A MR-PPAI or in a fonn approved by the
Director within 90 days of sampling. The report shall be submitted to the following address: Division of
Water Quality, Water Quality Section, Central Files, 1617 Mail Service Center, Raleigh, North Carolina
27699-1617.

NPDES Permit Requirements
Page 1 of 16
PART II
STANDARD CONDITIONS FOR NPDES PERMITS
Section A. Definitions
2/Month
Samples are collected twice per month with at least ten calendar days between sampling events.
3/Week
Samples are collected three times per week on three separate calendar days.
Act or "the Pic["
The Federal Water Pollution Control Act, also known as the Clean Water Act, as amended, 33 USC 1251, et. seq.
Annual Avcragg
The arithmetic mean of all "daily' discharges" of a pollutant measured during the calendar year. In the case of fecal
coliform, the geometric rnean of such discharges.
Arithmetic Mean
The summation of the individual values divided by the number of individual values.
lgypasa
The known diversion of waste streams from any portion of a treatment facility including the collection system, which
is not a designed or established or operating mode for the facility.
Calendar Day
The period from midnight of one day until midnight of the next day. However, for purposes of this permit, an
consecutive 24-hour pcnod that reasonably represents the calendar day may be used for sampling. y
Calendar Quarter
One of the following distinct periods: January through March, April through June,
October through December.
July through September, and
Composite Sample
A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100 rnl in
such a manner as to result in a total sample representative of the wastewater discharge during the sample period. The
Director may designate the most appropriate method (specific number and size of aliquots necessary, the time
interval between grab samples, etc.) on a case -by -case basis. Samples may be collected manually or automatically.
Composite samples may be obtained by the following methods:
(1) Continuous: a single, continuous sample collected over a 24-hour period proportional to the rate of Flow.
(2) Constant time/variable volume: a series of grab samples collected at equal
time intervals over a 24 ,ho
period of discharge and combined proportional to the rate of flow measured at the rim of individual sample
collection, or
(3) Variable time/constant volume: a series of grab samples of equal volume collected over a 24 hour period
with the time intervals between samples determined by a preset number of gallons passing the sampling
point. Flow measurement between sample intervals shall be determined by use of a flow recorder and
totaIi7er, and the preset gallon interval between sample collection fixed at no greater than 1/24 of the
expected total daily flow at the treatment system, or
(4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at
a constant time interval. This method may only be used in situations where effluent flow rates vary
less` than 15 percent: -The- grab samples- shall be- taken- at intervals of no greater than- 20 minutes- apart --
during any 24-hour period and must be of equal size and of no less than 100 milliliters. Use of this method
requires prior approval by the Director.

NPDES Permit Requirements
Page 2of16
In accordance with (4) above, influent grab samples shall not be collected more than once per hour.
Effluent grab samples shall not be collected more than once per hour except at wastewater treatment systems
having a detention time of greater than 24 hours. In such cases, effluent grab samples may be collected at
intervals evenly spaced over the 24-hour period that are equal in number of hours to the detention time of the
system in number of days. However, the interval between effluent grab samples may not exceed six hours nor
the number of samples less than four during a 24-hour sampling period.
Continuous flow measurement
Row monitoring that occurs without interruption throughout the operating hours of the facili
ty. Flow monitored continually except for the infrequent times when there may be no flow or for infrequent maintenance
activities on the flow device.
Daily Discharge
The discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the
calendar day for purposes of sampling, For pollutants measured in units of mass, the "daily discharge" is calculated as
the total mass of the pollutant discharged over the day. The "daily discharge"
concentration comprises the mean
concentration for a 24-hour sampling period as either a composite sample concentration or the arithmetic mean of all
grab samples collected during that period. (40 CFR 122.3)
The highest "daily discharge" during the calendar month.
Daily Sampling
Parameters requiring daily sampling shall be sampled 5 out of every 7 days per week unless otherwise specified in the
permit. The Division expects that sampling shall be conducted on weekdays except where holidays or other
disruptions of normal operations prevent weekday suppling- If sampling is required for all seven days of the week
for any permit pararneter(s), that re4 uirernent will be so noted on the Effluent Limitations and Monitorin Pa s .
g ge(}
D WQ or "the L7ivisi,
The Division of Water Quality, Department of Environment and Natural Resources.
EMC
The North Carolina Environmental Management Commission.
Facility Closure
The cessation of wastewater treatment at a permitted facility, or the cessation of all activities that r
under the NPDES.permit to be rescinded
Completion of facility closure will allow thise9 coverage
.
The Nth root of the product of the individual values where N = the number of individual
values. For purposes of
calculating the geometric mean, values of "0" (or "< [detection level]' shall be considered s
Grab Sample
Individual samples of at least 100 ml collected over a period of time not exceeding 15 minutes. Grab samples can be
collected manually. Grab samples must be representative of the discharge (or the receiving stream, for instream
samples).
Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act.
Insrantaneops flow measurement
A measure of flow taken at the time of sampling, when both the sample and flow will be representative of the total
discharge.

NPDES Permit Requirements
Page 3 of 16
Monthly Average (ccrncentattion iimts)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar month. In the case of fecal
conform, the geometric mean of such discharges.
Permit Issuing Authority
The Director of the Division of Water Quality.
Quarterly Average (concentration limit)
The average of all sarnp]es taken over a calendar quarter.
Severe property damage
Substantial physical damage to property, damage to the treatment facilities which causes them to become inoperable,
or substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a
bypass. Severe property damage excludes economic loss caused by delays in production.
Toxic Pollutant;
Any pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act.
Upset
An incident beyond the reasonable control of the Permitter causing unintentional and Temporary noncompliance with
permit effluent limitations and/or monitoring requirements An upset does not include noncompliance caused by
operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive
nnaint:.nance, or careless or improper operation.
Weekly Average (concentrationlii )
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar week In the case of fecal
conform, the geometric mean of such•discharges.
Section E. General Condition.
1. Duty to Comply
The Permitter must comply with all conditions of this permit. Any permit noncompliance constitutes a violation
of the Clean Water Act and is grounds for enforcement action; for permit termination, revocation and reissuance,
or modification; or denial of a permit renewal application [40 CFR 12241].
a. The Permittee shall comply with effluent standards or prohibitions established under section 307(a) of the
Clean Water Act for toxic pollutants and with standards for sewage sludge use or disposal established under
section 405(d) of the Clean Water Act within the time provided in the regulations that establish these
standards or prohibitions or standards for sewage sludge use or disposal, even if the permit has not yet been
modified to incorporate the requirement •
b. The Clean Water Act provides that any person who violates section 301, 302, 306, 307, 308, 318 or 405 of the
Act, or any permit condition or limitation implementing any such sections in a permit issued under section
402, or any requirement imposed in a pretreatment program approved under sections 402(a)(3) or 402(b)(8)
of the Act, is subject to a civil penalty not to exceed $25,000 per day for each violation. [40 CFR 12.2.4I (a)
(2)]
c. The Clean Water Act provides that any person who rreAgeg iy violates sections 301, 302, 305, 307, 308, 318, or
405 of the Act, or any condition or limitation implementing any of such sections in a permit issued under
section 402 of the Act, or any requirement imposed in a pretreatment program approved under section
402(2)(3) or 402(b)(8) of the Act, is subject to criminal penalties of 32,500 to $25,000 per day of violation, or
imprisonment of not more than 1 year, or both. In the case of a second or subsequent conviction for a
negligent violation, a person shall be subject to criminal penalties of not more than ;50,000 per day of
violation, or by imprisonment of not more than 2 years, or both. [40 CFR 122.41 (a) (2)]

NPDES Permit Requirements
Page 4 of 16
d. Any person who knowing y violates such sections, or such conditions or limitations is subject to criminal
penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3 years, or both. In
the case of a second or subsequent conviction for a knowing violation, a person shall be subject to criminal
penalties of not more than $100,000 per day of violation, or imprisonment of not more than 6 years, or both.
[40 CFR 122.41 (a) (2)]
e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or any permit
condition or limitation implementing any of such sections in a permit issued under section 402 of the Act,
and who knows at that time that he thereby places another person in imminent danger of death or serious
bodily injury, shall, upon conviction, be subject to a fine of not more than $250,000 or imprisonment of not
more than 15 years, or both. In the case of a second or subsequent conviction for a knowing endangerment
violation, a person shall be subject to a fine of not more than $500 000 or by 30 years, car both. An organization, as defined in section 309 c 3 ' imprisonment of not more than
of violating the imminent danger provision, be subject to a fine )(fnor more han�A000hall, upon can conviction
up to $2,000,000 for second or subsequent convictions. [40 CFR 122.41 (a)2 and be fiord
f. Under state law, a civil penalty of not more than 125,000 per violation may be assessed against any erson
who violates or fails to act in accordance with the terms, conditions, or re uir P
Carolina General Statutes § 143-215.6A] 4 ements of a permit [North
g. Any person may be assessed an administrative penalty by the Administrator
306, 307, 308, 318 or 405 of this Act, or any permit onditiolimitationrimplementing any301, violating section ofsuch
h
sections in a permit issued under section 402 of this Act. A
not to exceed $10,000 per violation, with the maximum amount of anyAdministrativepI penaltyens for Class I violations are
$25,000. Penalties for Class II violations are not to exceed $10,000 per rcassessed not to during cxceed
l violation2241 a continues, 3 with the maximum amount of any Class II penity knot f t each.
$12 �. 40 CFR
(a) (3)]
2. Duty to Mitiglitc
The Perrnitree shall fake all reasonable steps to minimize or prevent any discharge or sludge use or disposal in
violation of this permit which has a reasonable likelihood of adversely affecting hurnan health or the environ ent
[40 CFR 122.41 (d)].
3. Civil and Criminall.,iability
Except as provided in permit conditions on "Bypassing" (Part II. C. 4), "Upsets"
Failures" (Part II. C. 7), nothing in this permit shall be c v (Part II. C. 5) and Power
responsibilities, liabilities, or penalties for noncom construed to relieve the Permittee from any
of the Federal Act, 33 USC 1319. Furthermore, Pace pursuant to NCGS 143-215.3, 143-215.6 or Section 309
fish killui, even though the responsibility for effective compliance e Permittee
may be terra oorari! suspended_r 'ai damages, such as
P y
4. Oil ind Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the Permitter
from any responsibilities, liabilities, or penalties to which the Permittee is or may be subject to under NCGS 143-
215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321. Furthermore; the Permittee is responsible for
consequential damages; such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Prope[ly Rights
The issuance of this permit does not conveyanyproperty P Pay rights in either real or personal property, or any
exclusive privileges, nor does it authorize any injury
to any infringement of Federal, State or local laws or regulations
a[40 CFR e property
41 (g)]. invasion of personal rights, nor
6. On_shorc or Qfsshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical structures or
facilities or the undertaking of any work in any navigable waters.

NPDES Permit Requirements
Page 5 of 16
7. Severs bili ty
The provisions of this permit are severable. If any provision of this permit, or the application of any provision
permit to any circumstances, is held invalid, the application of such provision to other circumstances, and the rem
of this permit, shall not be affected thereby [NCGS 15OE0 23).
8. Duty to Provide Information
The Permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any inforrnauon which the
Permit Issuing Authority may request to determine whether cause exists for modifying,revoking and reissuing, or
terminating this permit or to determine compliance with this permit. The Permittee shall also furnish to the
Permit Issuing Authority upon request, copies of records required by this permit [40 CFR 122.41 (h)j.
9. Duty to Reapply
If the Permittee wishes to continue an activity regulated by this permit after the expiration date of this
Permittee must apply for and obtain a new permit [40 CFR 122.41 (b)]. Permit, the
10. Expiration of Putrut
The Permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the Permittee shall submit such information, forms, and
fees as axe required by the agency authorized to issue permits no later than 180 days prior to the expiration date.
Any Permittee that has not requested renewal at least 180 days prior to expiration, or anyp
have a permit after the expiration and has not requested renewal at least 180 dayst errnitteeo aio that subjects not
the Permittee to enforcement procedures as provided in NCGS 143-215.6 and 33 uSC: 1251 etseq.n, will
11. Signatory Requirements
applications, reports, or information submitted to the Permit Issuing Authority shall be signed and certified
[40 CFR 122.41 (k)].
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a responsible
corporate officer means: (a) a president, secretary, treasurer or vice
charge of a principal business function, or any other person whoperforms ofent the corporation reds in
making functions for the corporation, or the managersimilar policy production,
or decision
operating facilities, provided, the manageris authorized ofgre or more manufacturing, production, or
ern the
operation of the regulated facility including havingrxianagzrnent decisions which
ding the explicit or implicit duty of making rna� capital
investment recommendations, and initiating and directing other comprehensive term environmental compliance with environmental laws and regulations; the managergees to assure long
the necessary systems are established or actions taken to gather complete and accuraie iin of rmationtfoat
r
permit application requirements and where authority to sign documents has been assigned or delegated
to the manager in accordance with corporate procedures .
(2) For a partnership or sole proprietorship: by a generalpartner or the proprietor,
(3) For a municipality, State, Federal,P prietvr, respectively; or
ranking elected official [40 CFR 1other public agency: by either a principal executive officer or
b. All reports required by the permit and other information requested by the Permit Issuing Authority shall be
signed by a person described in paragraph a_ above or by a duly authorized representative of that person. A
person is a duly authorized representative only if:
1. The authorization is made in writing by a person described above;
2. The authorization specified either an individual or a position having responsibility for the overall
operation of the regulated facility or activity, such as the position of plant manager, operator of a well or
well field, superintendent, a position of equivalent responsibility, or an individual or position having
overall responsibility for environmental matters for the company. (A duly authorized representative may
thus be either a named individual or any individual occupying a named position.); and
3. The written authorization is submitted to the Permit Issuing Authority [40 CFR 122.22]

NPDES Permit Requirements
Page 6 of 16
c. Changes to authorization; If an authorization under paragraph
because a different individual or position has responsiilitor the )� of oseraationon S the longer accuratenew
authorization satisfying the requirements ofparagraphsectp of facility, a new
Director
prior to or together with any reports, inforation orf applications muston to bee signed
submitted tanthauthorized
representative [40 CFR 122.22]by authorized
d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make the
following certification (40 CFR 122.22]:
'1 certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel property gather and evaluate
the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate, and complete. 1 am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations.'
12. PcrrnitActiona
This permit may be modified, revolted and reissued or terminated
Permittee fora permit modification, revocation and reissuance,otermination, r a notification of request for cause. The filing of a bythe
changes or anticipated noncompliance does not stay any permit condition [40 CFR 122.41 ()]. P cd
13:
The issuance of this permit does not prohibit the permit issuing authority from reopening
permit, revoking and reissuing the permit, or terminating the permit as allowed by the laws, rules, and rreegulations
contained in Title 40, Code of Federal Regulations, Parts 122 and 123; Title 15A of the North Carolina
Administrative Code, Subchapter 2H .0100•, and North Carolina General Statute 143-215.1 et. al.
14.
The Permittee must pay the annual administering and compliance monitoring fee within
billed by the Division. Failure to pay the fee in a timelyA days after being
may cause this Division to
ate action to revoke the it accordance with 1 SA NCAC 2H.010S (b) (4)initiate
1. Certified Operator
classification of the permitted facility
Uponed water pollution control itte f act t9 by the Certification Commission the Prrrnittee shall employ a
system operator in responsible
control treatment system. Such operator must hold a certification of the charge (ORC) ofto the water pollution
classification assigned to the water pollution control treatment! equivalent or greater than the
Permittee roust also employ one or more certified Back-up ORCs who ❑ sy ess a e Certifiy cation Commission. The
type of the system. Back-up ORCs roust possess a grade equal to (or no ore than one valid
s than) the of the
grade
of the system [15A NCAC 8G.0201]_ gm
The ORC of each Class I facility must
Visit the facility at least weekly
> Comply with all other conditions of 15A NCAC 8G.0204.
The ORC of each Class II, III and IV facility must
➢ Visit the facility at least daily, excluding weekends and holidays
> Properly manage and document daily operation and maintenance of the facility
> Comply with aU other conditions of 1SA NCAC 8G.0204.
Once the facility is classified, the Permittee shall submit a letter to the Certification Commission des! atin
operator in responsible charge: gn g the
a. Within 60 calendar days prior to wastewater being introduced into a new system

Within 120 calendar days of:
Receiving notification of a change in the classification of the system requiring the designation of a
new ORC and back-up ORC
A vacancy in the position of ORC or back-up ORC.
2. Proper Operation and Maintenance
The Permittee shall at all times provide the operation and maintenance resources necessary to operate the existing
facilities at optimum efficiency. The Permittee shall at ail times properly operate and maintain all facilities and
systems of treatment and control (and related appurtenances) which are installed or used by the Permittee to
achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate
laboratory controls and appropriate quality assurance procedures. This provision requires the Perm.ittee to install
permit [40 CFR 122.41 (e)]..
and operate backup or auxiliary facilities only when necessary to achieve compliance with the conditions of the
3. Need to Halt or Recitact not a Defense
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this pernmit [40 CFR 122.41
(c)]•
4.
a_ Bypass not exceeding limitations [40 CFR 122.41 (m) (2)]
The Permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but
only if it alto is for essential maintenance to assure efficient operation. These bypasses are not subject to the
provisions of Paragraphs b. and c. of this section.
Notice [40 CFR 122.41 (m) (3)1
(1) Anticipated bypass. If the Permittee
notice, if possible at least ten days
anticipated quality and effect of the b
(2) Unanticipated bypass. The Permittee
II. E. 6. (24-hour notice).
c. Prohibition of Bypass
( Bypass from the treatment facility is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for bypass, unless:
(A) Bypass arcs unavoidable to prevent loss of life, personal injury or severe property tam (B) There were no feasible alternatives to the bypass, such as the use of auxiliary
retention of untreated wastes or during normal periods of treatment facilities,
maintenance merit downtime.
condition is not satisfied if adequate backup equipment equipment fie• T
reasonable engineering �� ui rent should have been installed in the exercise of
gmKang judgment to prevent a bypass which occurred during normal periods of
equipment downtime or preventive maintenance; and
(C) The Permittee submitted notices as required under Paragraph b. of this section.
(2) Bypass from the collection system is prohibited and the Permit Issuing Authority may take enforcement
action against 2 Permittee for a bypass as provided in any current or future system -wide collection system
permit associated with the treatment facility.
(3) The Permit Issuing Authority may approve an anticipated bypass, after considering
the Permit issuing Authority determines that it will meet the three conditions listed above in e Pararse ggraph of
(l) of this section.
b.
b.
NPDES Permit Requirements
Page 7 of 16
knows in advance of the need for a bypass, it shall submit prior
before the date of the bypass; including an evaluation of the
ypass.
shall submit notice of an unanticipated bypass as required in Part
5. Upsets
a. Effect of an upset [40 CFR 122.41(n)(2
)1: brought for upset
()1: An upset constitutes an affirmative defense to an action
noncompliance with such technology based permit effluent limitations if the requirements of
paragraph b. of this condition are met No determination made during administrative review of claims that

d. Burden of proof [40 CFR 122.41 (n) (4)]: The Permittee seeking to establish the occurrence of an
upset has the burden of proof in any enforcement proceeding.
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters
shall be utiiieed/disposed of in accordance with NCGS 143-215.1 and in a manner such as to prevent anypollutant
from such materials from entering waters of the State or navigable waters of the United States_ ThePerrtuttee
shall comply with all existing Federal regulations governing the disposal of sewage sludge. Upon promulgation of
40 CFR Part 503, any permit issued by the Permit Issuing Authority for the utilization/disposal of sludge may be
reopened and modified, or revoked and reissued, to incorporate applicable re
qements at 40 CPermittee shall comply with applicable 40 CFR 503 Standards for the Use and Disp sv al f Sewage Sludge 503. The
(when
promulgated) within the tune provided in the regulation, even if the permit is not modified to incorporate the
requirement. The Perrnittee shall notify the Permit Issuing Authority of any significant change in its sludgeuse
or disposal practices.
NPDES Permit Requirements
noncompliance was caused by upset, and before an action for noncompliance, is final a Page 8 actionot n
subject to judicial review. administrative
b. Conditions necessary for a demonstration of upset: A Perrnittee who wishes to establish the
other relevant evidence that:
eratin
affirmative defense of upset shall demonstrate, through properly signed, contemporaneous oo s or
P g iK
(1) An upset occurred and that the Perrtuttee can identify the cause(s) of the upset;
(2) The Permit -tee facility was at the time being properly operated; and
(3) The Permittee submitted notice of the upset as required in Part II. E. 6.
(of this permit.
(4) The Permittee complied with any remedial measures required under PartII. B.)2. of this permit.
7.
The Permitter is responsible for maintaining adequate safeguards Reliability) to prevent the discharge of untreated or inadequately hated wastes d� ele15Actrical
Naj p 2H.OI24
either by means of alternate power sources, standbyy g clereate pourer failures
generators or retention of inadequately treated effluent.
SectiogD. Monitoring and Records
1. lteprtsentative Sampling
Sarnples collected and measurements taken, as required herein, shall be characteristic of the volume and nature of
the permitted discharge. Samples Collected at a frequency
characteristic of the discharge less than daily shall be taken on a day and time that is
characteristic
� over the entire period the sample represents. All samples shall be taken at the
monitoring points specified in this permit and unless otherwise specified, before the effluent joins or is diluted
by any other wastestream, body of water, or substance. Monitotin
notification to and the approval of the Permit Issuing AuthorityC g points shall not be Cha.ngrd without
[40 Fx 122.41 �}a.
2. Batwing
Monitoring results obtained during the previous months shall be summarized monthly Discharge MonitoringReport(} ��� for each month and reported on a
Director, postmarked no later than the 2$�}f Fllorm (MR ovin 1, b P 3)alternative 2, ng period.
forms approved by the
day g the completed reporting period,
The first DMR is due on the last day of the month following
facility, on the last day of the month following the commenceement he issuance
chars permit orc in the case o ia new
these, and all other reports required herein, shall be submitted to the following address:
Duplicat�e signed copies of
NC DENR / Division of Water Quality / Water Quality Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

NPDES Permit Requirements
Page 9 of 16
3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected
and used to ensure the accuracy, and reliability of measurements of the volume of monitored discharges. The
devices shall be installed, calibrated and maintained to ensure that the accuracy of the measurements is consistent
with the accepted capability of that type of device. Devices selected shall be capable of measuring Bows with a
maximum deviation of less than 10% from the true discharge rates throughout the range of expected discharge
volumes. Flow measurement devices shall be accurately calibrated at a minimum of once per
to ensure that the accuracyyg
of the measurements is con;;istent with the accepted capability
of that typ maintained
The Director shall approve the flow measurement device and monitoring location prior to installatio0 of device.
Once -through condenser cooling water flow monitored by pump Logs
of this permit and based on the manufacturer's urn ' or pump hourmeters specified in Part I
p p curves shall not be subject to thiss requirement
4. Test Procedure%
Test procedures for the analysis of pollutants shall conform to the EMC regulations (published pursuant to
NCGS 143-215.63 et. seq.), the Water and Air Quality Reporting Acts, and to r
Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act (as Amended), regulations published CFR 06; or to
the case of sludge use or disposal, approVed under 40 CFR 136, unless otherwise specified in 4CFR 503, unless
� L3t5; or in
other test procedures have been specified in this permit [40 CFR 122.41].
To meet the intent of the monitoring required by this permit, all test procedures must
detection and reporting levels that are below the produce minimum
reported down to the mirLunum detection or lower reporting r discharge requirements and all data g��"ated must be
determined capable of achieving� rtirag level of the procedure. If no approved methods are
then the most sensitive (method minimum
the lowest rtection and possible detection coon and reporting orting levels below ply t a approved
discharge requirements, retho mGnr t
be used. f) approved method must
5. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly
monitoring device or rnethod required to be maintained under this tendons punished
any
a fine of not more than $10,000 per violation, or by imprisonment for permit
tsmore than upon two years conviction, perr violation,
iO] n, by
by both. If a conviction of a person is for a violation comnutted after a first conviction of such monde rot or
is
paragraph, punishment is a fine of nor more than $20,000 per day of violation, or byperson under o e
than 4 years, or both [40 CFR I2241]. imprisonment of not more
6. Records Retention
Except for records of monitoring information required by this permit related to the F
use and disposal activities, which shall be retained for a period of at least five longer as sewage sludge
y40
CFR 503), the Permitter shall retain records of all monitoring information, including; ( linger required by 40
> all calibration and maintenance records
> all original strip chart recordings for continuous monitoring instrumentation
➢ copies of all reports required by this permit
➢ copies of all data used to complete the application for this permit
These records or copies shall be maintained for a period of at least 3 years from the date of the sam le
time[4acFR
measurement, report or application. This period may be extended by request of the Director at anyp
122.41).
7. Recording Results
For each measurement or sample taken pursuant to the requirements of this
the following information [40 CFR 122.41]: Pert, the Pertnittee shall record
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;

e. The analytical techniques or methods used; and
f. The results of such analyses.
8 I cu d
The Permittee shall allow the Director, or an authorized representative (including an authorized contractor acting
as a representative of the Director), upon the presentation of credentials and other documents as ma be re uire
by law, to;
Y q d
a. Enter upon the Permittee's premises where a regulated facility or activity is located or conducted,
records must be kept under the conditions of this permit;
b. Have access to and copy, or where
at reasonable times, any records that must be kept under the conditions of this
permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment
or operations regulated or required under this permit; and d. Sample or monitor at reasonable times, for theu ), practices,
authorized by the Clean Water Ac anyp rposes of assuring permit compliance or as otherwise
t, substances or parameters at any location [4D CFR 122.41 (i)].
All discharges authorized herein shall be consistent with the terms and conditions of thispermit.
that authorized e
of any pollutant identified in this permit more frequently than or at a level in excess o
constitute a violation of the permit P remit The discharge
razed shall
NPDES Permit Requirements
Page 10 of 16
2.
The Pertnittee shall give notice to the Director as soon as possible of any planned physical alterations or
additions to the permitted facility [40 CFR 122.4I mi. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria
122.29 (b); or for new sources at 40 CFR
b. The alteration or addition could significantly change increasee nature or
discharged. This notification applies to pollutants subject neither to effluent limitations quantity
of
notification re ty pollutants
requirements under 40 CFR 122.42 (a) (I). the permit, nor to
c. The alteration or addition results in a significant change,
and such alternation, addition or change in the Ferrnit#ee s sludge use or disposal
from or absent in the addition
may justify the application of P practices,
existing permit, including notification of additional ordisposalsites not are r
during the permit application process or not reported
pursuant to an approved land application plan, reported
3. Aicilisagatejactarstouthaacc
The Permitter shall give advance notice to the
activities that might result in notice to Director of any planned changes to the
Permit [40 CFR. 1224I(2)].Permitted facility or other
4. Imam
This permit is not transferable to any person except after notice to the Director. The Direct
modification or revocation and reissuance of the permit to document the change
may incorporate other requirements as may be necessary of _ or may require
yunder the Dean Water Act ownership.
0 CFR Any such action
� ( 122.41FR
5. o t�) (3))
n
Monitoring results shall be reported at the intervals specified elsewhere in this permit [40 CFR 122.41
a. Monitoring results must be reported on a Discharge (1) (4)]-
provided by the Director for reporting results of mnitoring of sludge use or disposal practices.
Monitoring P (DER) (See Part II. D. 2) or forms
b. If the Permittee monitors any pollutant more frequently than required byp p ttCepermit, the r.
monitoring shall be included in the calculation and reporting of the data submitted on
the DM]t of such

NPDES Permit Requirements
Page 11 of 16
6. Twenty-four FInutJReporting
a. The Permittee shall report to the Director or the appropriate Regional Office any noncompliance that
potentially threatens public health or the environment. Any information shall be provided orally within 24
hours from the time the Permittee became aware of the circumstances. A written submission shall also be
provided within 5 days of the time the Permittee becomes aware of the circumstances. The written
submission shall contain a description of the noncompliance, and its cause; the period of noncompliance,
including exact dates and times, and if the noncompliance has not been corrected, the anticipated time it is
expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance [40 CFR 122.41 (1) (6)1.
b. The Director may waive the written report on a case -by -case basis for reports under this section if the oral
report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at [phone], [phone] or [phone].
7. Other Noncompliance
The Permittee shall report all instances of noncompliance not reported -under Part 1I. E. 5 and 6. of this permit at
the time monitoring reports are submitted. The reports shall contain the information listed in Part II. E 6. of
this permit [40 CFR 122.41 (1) (7)].
8. Other Information
Where the Perrnittee becomes aware that it failed to submit any relevant facts in a permit application, or
submitted incorrect information in a permit application or in any report to the Director, it shall promptly submit
such facts or information [40 CFR 122.41 (1) (8)1
9. Noncompliance Noilfisatiort
The Perrnittee shall report by telephone to either the central office or the appropriate regional office of the
Division as soon as possible, but in no case more than 24 hours or on the next working day following the
occurrence or first knowledge of the occurrence of any of the following
a. Any occurrence at the water pollution control facility which results in the di
wastes which are abnormal in quantityor charact_ dumpingtic, such as the of the sch oc of c ni#icats amounts of
digester, the known passage of a slug of hazardous substance through the facili y of a sludge
circumstances.
tY or any o other unusual
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate
wastewater treatment such as mechanical or electrical failures of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in 2 by-pass directly to receiving
waters without treatment of all or any portion of the influent to such station or facility.
Persons reporting such occurrences by telephone shall also file a written report within 5 days following first
knowledge of the occurrence.
10. Availability of Rcpottt
Except for data determined to be confidential under NCGS 143-215.3 (a)(2) or Section 308 of the Federal Act, 33
USC 1318, all reports prepared in accordance with the terms shall be available for public inspection at the offices
of the Division of Water Quality. As required by the Act, effluent data shall not be considered confidenti.aL
Knowingly making any false statement on any such report may result in the imposition of criminal penalties as
provided for in NCGS 143-215.1 (b)(2) or in Section 309 of the Federal Act.
11. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement, representation, or
certification in any record or other document submitted or required to be maintained under this permit, including
monitoring reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine of

NPDES Permit Requirements
Page 12 of 16
not more than $25,000 per violation, or by imprisonment for not more than two years per violation, or by both
[40 CFR 122.41].
12. Annual Performance Reports
Pernnttees who own or operate facilities that collect or treat municipal or domestic waste shall provide an annual
report to the Permit Issuing Authority and to the users/customers served by the Perrnittee (NCGS 143-215.1C).
The report shall summarize the performance of the collection or treatment system, as well as the extent to which
the facility was compliant with applicable Federal or State laws, regulations and rules pertaining to water quality.
The report shall be provided no later than sixty days after the end of the calendar or fiscal year, depending upon
which annual period is used for evaluation.
PART III
OTHER REQUIREMENTS
Section A. Construction
The Permittee shall not commence construction of wastewater treatment facilities, nor add to the plants treatment
capacity, nor change the treatment process(es) utilized at the treatment plant unless the Division has issued an
Authorization to Construct (AtC) permit- Issuance of an AtC will not occur until Final Plans and Specifications for
the proposed construction have been submitted by the Permittee and approved by the Division.
Section B. Groundwater Monitoring
The Permittee shall, upon written notice from the Director of the Division of Water Quality,
oundwater
monitoring as may be required to determine the compliance of this NPDES permitted facilitycondwith thegcurrentt
groundwater standards.
Section C. Changes in Discharges of Toxic Substances
The Permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe (40 CFR 122.42):
a. That any activity has occurred or will occur which would result in the discharge, on a routine or frequent
basis, of any toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the
following "notification levels";
(1) One hundred micrograms per liter (100 µg/L);
(2) Two hundred micrograms per liter (200 µg/L) for acrolein and acrylonitrile; five hundred micrograms
per liter (500 µg/L) for 24dinitraphenol and for 2-methyl-4.6-dinitrophenol; and one (1 mg/L) for antimony; gram per liter
(3) Five times the maximum concentration value reported for that pollutant in the permit application.
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine 'or
infrequent basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the
highest of the following "notification levels";
(I) Five hundred micrograms per liter (500/L);
(2) One milligram per liter (1 mg/L) for antimony;
(3) Ten times the maairnurn concentration value reported for that pollutant in the permit application.
Section D. Evaluation of Wastewater Discharge Alternatives
The Permittee shall evaluate all wastewater disposal alternatives and pursue the most environmentally sound
alternative of the reasonably cost effective alternatives. If the facility is in substantial non-compliance with the terms
and conditions of the NPDES permit or governing rules, regulations or laws, the Permittee shall submit a report in
such form and detail as required by the Division evaluating these alternatives and a plan of action within GO days of
notification by the Division.
Section E. Facility Closure Requirements
The Permittee must notify the Division at least 90 days prior to the closure of any wastewater treatment system
covered by this permit. The Division may require specific measures during deactivation of the system to prevent

NPDES Permit Requirements
adverse impacts to waters of the State. This permit cannot be rescinded while any activities re Page 13 of 16
uirin
continue at the permitted facility. q g this permit
PART IV
SPECIAL CONDITIONS FOR MUNCIPAL FACILITIES
5 tin u r t
ammuktammo
All POTWs must provide adequate notice to the Director of the following;
1. Any new introduction of pollutants into the POTW from an indirect discharger which would be subject to
2.
section 301 or 306 of CWA if it were directly discharging those pollutants; and
Any substantial change in the volume or character of pollutants being introduced by an indirect discharger
3.
as influent to that POTW at the time of issuance of the permit.
For purposes of this paragraph, adequate notice shall include information on (1) the quality
effluent introduced into the POTW, and (2) any anticipated impact of the change on the quantity orn f
of effluent to be discharged from the POTWquality
Effluent limitations are listed in Part 1 of this permit. Other pollutants attributable to inputs from
industries using the municipal system may be present in the Permittee's discharge. At such rime as
sufficient information becomes available to establish limitations for such pollutants, this
permitrevised to specify effluent limitations for any or all of such other pollutants in accordan,witha b esb t
practicable technology or water quality standards.
2. Under no circumstances shall the Permittee allow introduction of the following wastes in the waste
treatment system: •
a. Pollutants which create a fire or explosion hazard in the POTW, includin
wastestreuns with a closed cup flashpoint of less than 140 degrees Fahrenheit or 60 dg• but not deg to,
Centigrade using the test methods specified in 40 CFR 261.21; degto,
b. Pollutants which will cause corrosive structxustl damage to the POTW, but in no case
with pH lower than 5.0, unless the works is s fi Discharges
c Solid or viscous pollutants in amounts F� � designed to arcommndate such Discharges;
resulting in Interference; which will cuae obstruction to the flow in the POTW
d. Any pollutant, including oxygen demanding pollutants (EOD, etc) released in a Discharge
rare and/or pollutant concentration whicharge at a flow
e. Heat in amounts which will � will cruse Interference with the POTW;
inhibit biological activity in the POTW resulting in Interference, but in
(104°no case heat in such quantities that the temperature at the POTW Treatment Plant exceeds 40QC
F) unless the Division, upon request of the POTW, approves alternate temperature limits;
f. Petroleum nil, nonbiodegradable cutting oil, or products of mineral oil origin in amounts that will
cause interference or pass through;
g. Pollutants which result in the presence of toxic gases, vapors,
or fumes within
quantity that may cause acute worker health and safety problems; the POTW in a
h. Any trucked or hauled pollutants, except at discharge points designated by the POTW.
1.
4. The Permittee shall require any industrial discharges sending influent to the
Federal Pretreatment Standards promulgated in response to Section 307(b)the petted iortto toacc meet
ofeptin
wastewater from any significant industrial user, the Permittee shall eitherdevelop and submit to the
3. With regard to the effluent requirements listed in Part I of this Permittee to supplement the requirements of the Federal Pretreatment permit,it
40 necessary
ecessar t for the
ensure compliance by the Permittee with all applicable effluent limitations. Such actions byPart rmi to
may be necessary regarding some or all of the industries discharging to the municipal system. the Per2xtittee

NPDES Permit Requirements
Pa
e 14 of 16
Division a Pretreatment Program for approval per 15A NCAC 2H .0907(a) or modify anexistingPretreatment Program per 15A NCAC 2H .0907(b).
5. This permit shall be modified, or alternatively, revoked and reissued, to incorporate or modify an approved
POTW Pretreatment Program or to include a compliance schedule for the developrnent of a POTW
Pretreatment Program as required under Section 402(b)(8) of the Clean Water Act and implementin
regulations or by the requirements of the approved State pretreatment program, as appropriate. g
Section C. Pretreatment Program$
Under authority of sections 307(b) and (c) and 402(b)(8) of the Clean Water Act and implementing relations 40
CFR Part 403, North Carolina General Statute 143-215.3 (14) and implementing regulations 15A NCAC 2H
.0900, and in accordance with the approved pretreatment program, all provisions and regulations contained and
referenced in the Pretreatment Program Submittal are an enforceable part of this permit.
The Permitter shall operate its approved pretreatment program in accordance with Section 402 8
Water Act, the Federal Pretreatment Regulations 40 CFR Part 403, the State PretreatmenttR{ � itheon Clean
NCAC 2.H .0900, and the legal authorities, policies, procedures, and financial provisionsbona 15ts
d in its
pretreatment program submission and Division approved modifications there of. Suoperation shall include
but is not limited to the implementation of the following conditions and requirements:
1.
2. Industrial Wane Sur„ey_Mal
The Permittee shall update its Industrial Waste
system at Least once every five years.
3. Monitoring Plan
The Permittee shall maintain adequate legal authority to implement its approved pretreatment program.
Survey (IWS) to include all users of the sewer collection
The Permittee shall implement a Division approved Monitoring Plan for the collection of facility specific
data to be used in a wastewater treatment plant Headworks Analysis (HWA) for the development of
specific pretreatment local limits. Effluent data from the Plan shall be reported on the DMRs (as required
by Part II, Section D, and Section E5.).
4.azglsystrisLAnalyzmximatindicrawautz
e ThPermittee shall obtain Division
Ths,and as reapproval of a Headworks Analysis (HWA) at least once every five
9� by the Division. Within 180 days of the effective date of this
subsequent permit modification) the Permittee shall submit to the Division a written permit evaluation
any
of the need to revise local limits (i.e., an updated HWA or documentation of why one etchoneeded) [40
CFR 122.421. The Permitter shall develop, in accordance with 40 CFR 403.5(c) and 15A NCAC 2H-.0909,
specific Local Limits to implement the prohibitions listed in 40 CFR 403.5(a) and (b) and I 5A NCAC 2H
.0909.
5. I d
e
In accordance with NCGS 143-215.1, the Permitter shall issue to all significant industrial users permits
operation of pretreatment equipment and discharge to the Permirtee's treatment works. 'These permits
shallshall contain limitations, sampling protocols, reporting re '
conditions, and compliance schedules as necessary gfor the installation appropriate
trestandard
tm treatment dandd special
control
technologies to assure that their wastewater discharge will meet all applicable pretreatment standards and
requirements. The Permittee shall maintain a current Allocation Table (AT) which surnma izes the results
of the Headworks Analysis (HWA) and the limits from all Industrial User Pretreatment Permits OUP).
Permitted IUP loadings for each parameter cannot exceed the treatment capacity of }
determined by the HWA. P tY the POTW as

NPDES Permit Requirements
Page 15 of 16
6. Au
The Pern ittee shall ensure that an Authorization to Construct permit (AtC) is issued to all applicable
industrial users for the construction or modification of any pretreatment facility. Prior to the issuance of
an AtC, the proposed pretreatment facility and treatment process roust be evaluated for its capacity to
comply with all Industrial User Pretreatment Permit (IUP) limitations,
7. P $ i
The Permittee shall conduct inspection, surveillance, and monitoring activities as described in its Division
approved pretreatment program in order to determine, independent of information supplied by industrial
users, compliance with applicable pretreatment standards. The Pertmatee must
a- b. Inspect all Significant Industrial Users (SIUs) at least once per calendar year; and
Sample all Significant Industrial Users (SIUs) at least twice per calendar year for allpermit-
limited pollutants, once during the period from January 1 through June 30 and once during the
period from July 1 through December 31, except for organic compounds which shall be sampled
once per calendar year,,
8. SI / Self M.onitorintr and Foortint
The permittee shall require all industrial users to comply with the applicable monitoring and reporting
requirements outlined its the Division approved pretreatment program, the industry's pretreatment permit,
or in 15A NCAC 2H .pr}{lg..
9.
The Perm ttee shall enforce and obtain appropriate remedies for violations of all pretreatment standards
promulgated pursuant to section 307(b) and (c) of the Clean Water Act (40 CFR 40
5 et. seq.), prohibitive
discharge standards as set forth in.40 CFR 403.5 and 1 SA NCAC 214 .0909, and specs local limitatio.
Al] enforcement actions shall be consistent with the Enforcement Response Plan approved
Division, �') pp vved by the
10: EretrcalznearAnoukuummval
The Pcrnuttee shall report to the Division in accordance with I5A NCAC
annual reports, Modified Pretreatment Programs developed under 15A NCAC08, in 0e0 of904 mattibe
required to meet with Division personnel periodically to discuss enforcement of pretreatment requirements
and other pretreatment implementation issues.
For all other active pretreatment programs, the Permittee shall submit two copies of a Pretreatment Annual
Report (PAR) describing its pretreatment activities over the previous twelve months to the Division at the
following address:
NC DENR / DWQ / Pretreatment Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
These reports shall be submitted according to a schedule established by the Director and shall contain the
following
a) Nattative
A brief discussion of reasons for, status of, and actions taken for all Significant Industrial
Users (SIUs) in Significant Non -Compliance (SNC);
b.) Pre um
A pretreatment grogram s
c.) 5i c t a wry (PPS) on specific forms approved by the Division;
a ce R
The nature of the violations and the actions taken or proposed to correct the violations on
specific forms approved by the Division;
d.) Indus ata Su a

e.)
NPDES Permit Requirements
'
age 16 of 16
Monitoring data from samples collected by both the POTW and the SignificantIndustrial
User (SIU). These analytical results must be reported on Industrial Data Summary Forms
(IDSF) or other specific format approved by the Division;
t f
Copies of the POTW s allocation table, new or modified enforcement compliance schedules,
public notice of Sills in SNC, and any other information, upon request, which in the
opinion of the Director is needed to determine compliance with the pretreatment
implementation requirements of this permit;
11. Public Notice
The Permittee shall publish annually a list of Significant Industrial Users (Sills) that were in Significant
Non -Compliance (SNC) as defined in the Permittee's Division approved Sewer Use Ordinance with
applicable pretreatment requirements and standards during the previous twelve month period. This list
shall be published within four months of the applicable twelve-month period.
1 2_ Recgr4 Keeping
The Permitter shall retain for a minimum of three years records of monitoring activities and results, along
with support information including general records, water quality records, and records of industrial impact
out the POTW.
•
13b Funding and Repo
The Permitter shall maintain adequate funding and staffing levelsto accomplish the objectives o
approved pretreatment programfits•
14. tladtkalaonicaNcitanaltatiragnau
Modifications to the approved pretreatment program' including but not limited to local limits
modifications, POTW monitoring of. their Significant Industrial. Monitoring
modifications, shall be considered a permit modification and shall be governedrby)15aNCAC 2/-1 .0114 and
15A NCAC 2H .0907..

Appendix 3.1— PGI Pretreatment Permit

Town of Benson
Control Authority and/or Municipality
PERMIT
Industrial User Pretreatment Permit (IUP)
To Discharge Wastewater Under the
Industrial Pretreatment Program
0001
IUP Number
410 subpart H
40 CFR Category
(if Applicable)
In compliance with the provisions of North Carolina General Statute 143-215.1, any
applicable federal categorical pretreatment regulations, all other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Control Authority and/or Municipality Sewer Use Ordinance. The
following Industry, hereafter referred to by name or as the permittee:
Industry name, permittee:
PGI Nonwovens dba Chicopee, Inc.
Facility Located at Street Address
1203 Chicopee Road
City
Benson
State, Zip
North Carolina, 27504
is hereby authorized to discharge wastewater from the facility located at the above listed
address into the sanitary sewer collection system and the wastewater treatment facility of
the Control Authority and/or Municipality listed below:
IUP Control Authority and/or Municipality WWTP name:
Town of Benson WWTP
NPDES Number:
NC0020389
WWTP Address:
770 Hannah Creek Road
City, State, Zip
Four Oaks, North Carolina 27524
in accordance with effluent limitations, monitoring requirements, and all other conditions
set forth in Parts I, II, and III of this Industrial User Pretreatment Permit (IUP).
Effective date, this permit and the authorization to discharge shell become effective at midnight
on this date:.
January 1, 2007
Expiration date, this permit and the authorization to discharge shall expire at midnight on this
date:
December 31, 2011
Date signed
Keith Langdon, Town Manager

Industrial User Pretreatment Permit (IUP)
PART I
Specific Conditions
IUP, PART I, OUTLINE:
A.)
B.)
C.)
D.)
E.)
F.)
G.)
IUP Basic Information
IUP Modification History
Authorization Statement
Description of Discharges
Schematic and Monitoring Locations
Effluent Limits & Monitoring Requirements
Definitions and Limit Page(s) notes
A. IUP Basic Information:
Receiving Control Authority & WWTP name .
Town of Benson WWTP
POTW NPDES # :
NC0020389
IUP Name :
PGI Nonwovens d.b.a. Chicopee, Inc.
IUP Number :
0001
IUP Effective date :
January 1, 2002
Pipe Numbers, list all regulated pipes:
001
IUP Expiration date :
December 31, 2006
IUP 40 CFR # (if applicable), or N/A:
410
B. IUP History:
Dates Modified:
July 24, 1998
June 16, 1999
July 29,1999
November 11, 1999
July 10, 2000
December 28, 2000
March 26, 2001
July 10, 2001
December 17, 2001
January 1, 2007
Modified IUP effective date to August 1, 1998 and expiration date to June 30,
1999.
Extended IUP from July 1, 1999 to August 1, 1999.
Extended IUP from September 1, 1999 to November 31, 1999.
Extended IUP from November 31, 1999 to December 31, 2000.
Sampling for Cyanide, Silver, .Arsenic, Cadmium, Total Chromium, Copper,
Mercury, Nickel, Lead & Zinc removed
Extended IUP from January 1, 2001 to March 31, 2001.
Extended IUP from April 1, 2001 to June 30, 2001.
Extended IUP effective date to July 10, 2001 and expiration date to December
31, 2001. Changed name from "Chicopee, Inc. Subsidiary of the Polymer
Group" to 'PGI Nonwovens d.b.a. Chicopee, Inc."
Renewed LUP from January 1, 2002 to December 31, 2006 with existing limits.
Requested daily max flow limit of 0.800 mgd denied. Requested TSS
concentration limit changed to mass based limit..
Permit Renewal and Modification: Reduced Flow, BOD, Ammonia and TP
limits. Added Cu, Oil & Grease, Pb, Ni, TN, TSS and Zn limits. Added Bis (2-
ethylhexyl) phthalate and Mo monitoring requirements.
2

Industrial User Pretreatment Permit (IUP)
PART I
Specific Conditions
C.) Authorization Statement:
1.) The Permittee is hereby authorized to discharge wastewater in accordance
with the effluent limitations, monitoring requirements, and all other conditions
set forth in this Industrial User Pretreatment Permit (IUP) into the sewer
collection system and wastewater treatment facility of the Control Authority
and/or Municipality.
2.) The Permittee is hereby authorized to continue operation of and discharge
wastewater from the following treatment or pretreatment facilities. These
facilities must correspond to the treatment units listed on both the application
and inspection forms.
IU Treatment Units
List all Treatment Units: Descriptions:
Flow Equalization 1.25 million gallons
Dissolved Air
Flotation
Filtration
Flocculation
Grease Trap
Screening
3.) The Permittee is hereby authorized to, if required by the Control Authority
and/or Municipality and after receiving Authorization to Construct (A to C)
from the Control Authority and/or Municipality, construct and operate
additional pretreatment units as needed to meet final effluent limitations.
D.) Description of IUP Discharge(s):
1. Describe the discharge(s) from all regulated pipes.
Pipe # 001 , Description of Discharge:
Chicopee is divided into two (2) plant divisions with separate 6" discharge lines
that merge into a single discharge line approx. 500 feet after pretreatment before
entering a combination metering and sampling vault. The combined discharge
enters the Town's sanitary sewer by tying into the Chicopee lift station force main
approximately 150 feet east of the lift station. The Chicopee lift station is located
on the north side of South Market Street approximately 200 yards from the
intersection of Chicopee Road and Market Street Extension.
3

Industrial User Pretreatment Permit (IUP)
PART I
Specific Conditions
E.) Schematic and Monitoring Locations:
The facility schematic and description of monitoring location(s) given below must
show enough detail such that someone unfamiliar with the facility could readily find
and identify the monitoring location(s) and connection to the sewer. Include and
identify all regulated pipes.
Ta Berznon
Lilt S GraYtty Main horn
L Environmental Fillers Inc.
Farce Maki
Market St
to Benson
South Market St Etd. ' -
i
(SR-1204)
Pars Sampling & .�.
Flow Meter Vault
North
deed end road
ak Combined PGI
Dacha Fripe 1a001
6"FM
Duch?torn
PGI's EF section
6' FM
Dieeharge tram
PGI'a DF section
4

PGI Nonwovens
NC0020389
Required
Laboratory
Detection
Level
I
N
N
1
.;
0
OTHER PARAMETERS; Please List Alphabetically
0.1
O
N
O
0
O
""
r-,
O
N
^"
O
O
11
Sample
Collection
Method
(C or G)
meter
00007
00
00
000(
00
Monitoring Frequency
By POTW
N
N
N
N
2/yr.
N
N
N
2/yr.
N
N
N
N
P
rn
pq
O
O
O
1/mo.
O
G
O
O
C
C
O
O
1/mo.
Mass Limits
Units
1
1
1
1
1
1
11
1
1
1
1
Monthly
Average
1
1
11
1
1
11
1
1
1
1
1
Daily Max
1
1
1
1
1
1
11
1
1
1
1
[
Concentration Limits
oA��o
o
Er
�'
tt
E
a
e�o�-1o�'o�e�o�le?j
=
a
o
E
E
0
Monthly
Avers e
C
O1
^
100
,
monitor
00
N
O
enN
monitor 1
OZ
300 1
'1")
200
id
c1r?
I()
O
I
1
(n
O1
in
1
1
1
1
1
1
1
1
1
1
O
.1..
O
act
TSS
Temperature
ce
0
Bis (2-ethylhexyl)
phthalate
0
a.
U
ce
1 1
g
0
O
�,
v
Z
Nitrogen, Total
Oil & Grease
Phosphorus, Total
Zinc
•-+
N
M
in
,,O
l,
00
01
O2
,^"_,
,-1,�.
"O
,—,
00
O1
0

Industrial User Pretreatment Permit (IUP)
PART I
Specific Conditions
G.) Definitions and Limit Page(s) notes:
In addition to the definitions in the Town of Benson's Sewer Use Ordinance the
following definitions apply:
1. Composite Sample:
Unless defined differently below, a composite sample for the monitoring
requirements of this IUP, is defined as the automatic or manual collection
of one grab sample of constant volume, not less than 100 ml, collected
every hour during the entire discharge period on the sampling day.
Sampling day shall be a typical production, and discharge day.
2. Composite Sample, alternative definition:
A composite sample for the monitoring requirements of this IUP is the
same as described above unless specifically defined below as the
automatic or manual collection of constant volume and constant time grab
samples collected and composited according to the following criteria:
specific volume of each grab sample =
specific time interval between samples =
total duration of sample collection period =
total number of grab samples to be composited =
n/a
n/a
n/a
n/a
milliliters
hours
hours
samples
3. Daily Monitoring Frequency
Daily Monitoring Frequency as specified in this IUP shall mean each
working day.
4. Grab Sample
Grab sample for the monitoring requirements of this IUP, is defined as a
single "dip and take" sample collected at a representative point in the
discharge stream.
5. Instantaneous measurement
An Instantaneous measurement for the monitoring requirements of this
IUP is defined as a single reading, observation, or measurement.
6

Industrial User Pretreatment Permit (IUP)
PART I
Specific Conditions
G.) Definitions and Limit Page(s) notes: (continued)
6. Monitoring and Reporting
All Monitoring shall be performed by a state certified laboratory by
standard methods. All data shall be reported to the Division as specified
in Part II, 2 of this permit, note that violations shall be reported within 24
hours, and that all sampling (even if done more frequently than required)
shall be summarized on forms approved by the Division and sent to the
following addresses:
Mr. Martin Morris, Superintendent
Town of Benson WWTP
770 Hannah Creek Road
Four Oaks, North Carolina 27524
7 Notice to Permittees
Permittee is subject to the thirty (30) general conditions attached in Part II
of this permit.
7

Industrial User Pretreatment Permit (IUP)
PART II
General Conditions
Outline of PART II,
1. Representative Sampling
2. Reporting
3. Test Procedures
4. Additional Monitoring by
Permittee
5. Duty to comply
6. Duty to Mitigate
7. Facilities Operation, Bypass
8. Removed substances
9. Upset Conditions
10. Right of Entry
11. Availability of Records
12. Duty to provide information
13. Signatory Requirements
14. Toxic Pollutants
15. Civil and Criminal Liability
16. Federal and/or State Laws
17. Penalties
18. Need to Halt or Reduce
19. Transferability
20. Property Rights
21. Severability
22. Modification, Revocation,
Termination
23. Reapplication
24. Dilution Prohibition
25. Reports of Changed Conditions
26. Construction of pretreatment
facilities
27. Reopener
28. Categorical Reopener
29. General Prohibitive Standards
30. Reports of Potential Problems
1. Representative Sampling
Samples and measurements taken as required herein shall be representative of the volume and
nature of the monitored discharge. All samples shall be taken at the monitoring points specified in
this permit and, unless otherwise specified, before the effluent joins or is diluted by any other
wastestream, body of water, or substance. Monitoring points shall not be changed without
notification to, and approval by, the permit issuing authority.
2. Reporting
a.) Monitoring results obtained by the permittee shall be reported on forms specified by the
Control Authority and/or Municipality and Division of Environmental Management,
postmarked no later than the twentieth day of the month following the month in which the
samples were taken. If no discharge occurs during a reporting period (herein defined as
each calendar month) in which a sampling event was to have occurred, a form with the
phrase "no discharge" shall be submitted. Copies of these and all other reports required
herein shall be submitted to the Control Authority and/or Municipality.
b.) If the sampling performed by the permittee indicates a violation, the permittee shall notify
the Control Authority and/or Municipality within 24 hours of becoming aware of the
violation. The permittee shall also repeat the sampling and analysis and submit the results
of the repeat analysis to the Control Authority and/or Municipality within 30 days after
becoming aware of the violation.
8

Industrial User Pretreatment Permit (IUP)
PART II
General Conditions
3. Test Procedures
Test procedures for the analysis of pollutants shall be performed in accordance with the techniques
prescribed in 40 CFR part 136 and amendments thereto unless specified otherwise in the
monitoring conditions of this permit.
4. Additional Monitoring by Permittee
If the permittee monitors any pollutant at the location(s) designated herein more frequently than
required by this permit, using approved analytical methods as specified above, the results of such
monitoring shall be submitted to the Control Authority and/or Municipality. The Control
Authority and/or Municipality may require more frequent monitoring or the monitoring of other
pollutants not required in this permit by written notification.
5. Duty to Comply
The permittee must comply with all conditions of this permit. Any permit noncompliance
constitutes a violation of the Control Authority and/or Municipality Sewer Use Ordinance and is
grounds for possible enforcement action.
6. Duty to Mitigate - Prevention of Adverse Impact
The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of
this permit which has a reasonable likelihood of adversely affecting human health, the POTW, the
waters receiving the POTW's discharge, or the environment.
7. Facilities Operation, Bypass
The permittee shall at all times maintain in good working order and operate as efficiently as
possible, all control facilities or systems installed or used by the permittee to achieve compliance
with the terms and conditions of this permit. Bypass of treatment facilities is prohibited except
when approved in advance by the Control Authority and/or Municipality. Bypass approval shall
be given only when such bypass is in compliance with 40 CFR 403.17.
8. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control
of wastewaters shall be disposed of in a manner such as to prevent any pollutants from such
materials from entering the sewer system. The permittee is responsible for assuring its compliance
with any requirements regarding the generation, treatment, storage, and/or disposal of "Hazardous
waste" as defined under the Federal Resource Conservation and Recovery Act.
9. Upset Conditions
An "upset" means an exceptional incident in which there is an unintentional and temporary
noncompliance with the effluent limitations of this permit because of factors beyond the reasonable
control of the permittee. An upset does not include noncompliance to the extent caused by
operational error, improperly designed or inadequate treatment facilities, lack of preventative
maintenance, or careless or improper operations.
An upset may constitute an affirmative defense for action brought for the noncompliance. The
permittee has the burden of proof to provide evidence and demonstrate that none of the factors
specifically listed above were responsible for the noncompliance.
10. Right of Entry
The permittee shall allow the staff of the State of North Carolina Department of Environment,
Health, and Natural Resources, Division of Environmental Management, the Regional
9

Industrial User Pretreatment Permit (IUP)
PART II
General Conditions
Administrator of the Environmental Protection Agency, the Control Authority and/or Municipality,
and/or their authorized representatives, upon the presentation of credentials:
1. To enter upon the permittee's premises where a real or potential discharge is located or
in which records are required to be kept under the terms and conditions of this permit;
and
2. At reasonable times to have access to and copy records required to be kept under the
terms and conditions of this permit; to inspect any monitoring equipment or monitoring
method required in this permit; and to sample any discharge of pollutants.
11. Availability of Records and Reports
The permittee shall retain records of all monitoring information, including all calibration and
maintenance records as well as copies of reports and information used to complete the application
for this permit for at least three years. All records that pertain to matters that are subject to any
type of enforcement action shall be retained and preserved by the permittee until all enforcement
activities have concluded and all periods of limitation with respect to any and all appeals have
expired.
Except for data determined to be confidential under the Sewer Use Ordinance, all reports prepared
in accordance with terms of this permit shall be available for public inspection at the Control
Authority and/or Municipality. As required by the Sewer Use Ordinance, effluent data shall not be
considered confidential.
12. Duty to Provide Information
The permittee shall furnish to the Director of Public Works or his/her designees, within a
reasonable time, any information which the Director, his/her designee, or the Division of
Environmental Management may request to determine whether cause exists for modifying,
revoking and reissuing, or terminating this permit or to determine compliance with this permit.
The permittee shall also furnish, upon request, copies of records required to be kept by this permit.
13. Signatory Requirements
All reports or information submitted pursuant to the requirements of this permit must be signed and
certified by a ranking official or duly authorized agent of the permittee.
14. Toxic Pollutants
If a toxic effluent standard or prohibition (including any schedule of compliance specified in such
effluent standard or prohibition) is established under Section 307(a) of the Federal Clean Water
Act for a toxic pollutant which is present in the discharge and such standard or prohibition is more
stringent than any limitation for such pollutant in this permit, this permit may be revised or
modified in accordance with the toxic effluent standard or prohibition and the permittee so
notified.
15. Civil and Criminal Liability
Nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties
for noncompliance.
16. Federal and/or State Laws
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve
the permittee from any responsibilities, liabilities, or penalties established pursuant to any
applicable Federal and/or State law or regulation.
10

Industrial User Pretreatment Permit (IUP)
PART II
General Conditions
17. Penalties
The Sewer Use Ordinance of the Control Authority and/or Municipality provides that any person
who violates a permit condition is subject to a civil penalty not to exceed $25,000 dollars per day
of such violation.
Under state law, (NCGS 143-215.6B), under certain circumstances it is a crime to violate terms,
conditions, or requirements of pretreatment permits. It is a crime to knowingly make any false
statement, representation, or certification in any record or other document submitted or required to
be maintained under this permit, including monitoring reports or reports of compliance or
noncompliance. These crimes. are enforced at the prosecutorial discretion of the local District
Attorney.
18. Need to Halt or Reduce not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessary
to halt or reduce the permitted activity to maintain compliance with the conditions of the permit.
19. Transferability
This permit shall not be reassigned or transferred or sold to a new owner, new user, different
premises, or a new or changed operation without approval of the Town.
20. Property Rights
This permit does not convey any property rights in either real or personal property, or any
exclusive privileges, nor does it authorize any injury to private property or any invasion of
personal rights, nor any infringement of Federal, State or local laws or regulations.
21. Severability
The provisions of this permit are severable and, if any provision of this permit or the application of
any provision of this permit to any circumstance is held invalid, the application of such provision
to other circumstances and the remainder of this permit shall not be affected thereby.
22. Permit Modification, Revocation, Termination
This permit may be modified, revoked and reissued or terminated with cause in accordance to the
requirements of the Control Authority and/or Municipality Sewer Use Ordinance and North
Carolina General Statute or implementing regulations.
23. Re -Application for Permit Renewal
The permittee is responsible for filing an application for reissuance of this permit at least 180 days
prior to its expiration date.
24. Dilution Prohibition
The permittee shall not increase the use of potable or process water or in any other way attempt to
dilute the discharge as a partial or complete substitute for adequate treatment to achieve
compliance with the limitations contained in this permit.
25. Reports of Changed conditions
The permittee shall give notice to the Control Authority and/or Municipality of any planned
significant changes to the permittee's operations or system which might alter the nature, quality, or
volume of its wastewater at least 180 days before the change.
11

Industrial User Pretreatment Permit (IUP)
PART II
General Conditions
26. Construction
No construction of pretreatment facilities or additions thereto shall be begun until Final Plans and
Specifications have been submitted to the Control Authority and/or Municipality and written
approval and an Authorization to Construct (A to C) have been issued.
27. Reopener
The permit shall be modified or, alternatively, revoked and reissued to comply with any applicable
effluent standard or limitation for the control of any pollutant shown to contribute to toxicity of the
WWTP effluent or any pollutant that is otherwise limited by the POTW discharge permit. The
permit as modified or reissued under this paragraph may also contain any other requirements of
State or Federal pretreatment regulations then applicable.
28. Categorical Reopener
This permit shall be modified, or alternatively, revoked and reissued, to comply with any
applicable effluent standard or limitation issued or approved under Sections 302(b)(2)(C) and (D),
304(b)(2), and 307(a)(2) of the Clean Water Act, if the effluent standard or limitation so issued or
approved:
1.) contains different conditions or is otherwise more stringent than any effluent
limitation in this permit; or
2.) controls any pollutant not limited in this permit.
The permit as modified or reissued under this paragraph shall also contain any other requirements
of the Act then applicable.
29. General Prohibitive Standards
The permittee shall comply with the general prohibitive discharge standards in 40 CFR 403.5 (a)
and (b) of the Federal pretreatment regulations.
30. Reports of Potential Problems
The permittee shall notify by telephone the Control Authority and/or Municipality immediately of
all discharges that could cause problems to the POTW including any slug loadings as defined by
40 CFR 403.5(b). If the permittee experiences such a discharge, they shall inform the Control
Authority and/or Municipality immediately upon the first awareness of the commencement of the
discharge. Notification shall include location of the discharge, type of waste, concentration and
volume if known and corrective actions taken by the permittee. A written follow-up report thereof
shall be filed by the permittee within five (5) days, unless waived by the Control Authority and/or
Municipality.
12

Industrial User Pretreatment Permit (IUP)
PART III
Special Conditions
1. Slug/Spill Control Plan
The Permittee shall provide protection from accidental and slug discharges of
prohibited materials and other substances regulated by this permit. The Permittee
shall develop a written slug/spill control plan and submit it to the Town of Benson
for the approval by the Town of Benson. The plan shall include, but is not limited
to:
• description of discharge practices, including non -routine batch discharges
• description of stored chemicals
• procedures for immediately notifying the POTW of slug discharges that
would cause a violation of 40 CFR 403.5(b), with procedures for follow
up notification within 5 days;
• and if necessary, procedures to prevent adverse impact from accidental
spills, including inspection and maintenance of storage areas, handling and
transfer of materials, loading and unloading operations, control of plant
site run-off, worker training, building of containment structures or
equipment, measures for containing toxic organic pollutants (including
solvents), and/or measures and equipment for emergency response.
2. Sludge Management Plan
Ninety days prior to the initial disposal of sludge generated by any pretreatment
facility, the permittee shall submit a sludge management plan to the Town of
Benson.
3. Flow Measurement Requirements
The Permittee shall maintain appropriate discharge flow measurement devices and
methods consistent with approved scientific practices to ensure the accuracy and
reliability of measurements of the volume of monitored discharges. Devices
installed shall be a continuous recording flow meter capable of measuring flows
with a maximum deviation of less than 10% from true discharge rates throughout
the range of expected discharge volumes. The devices shall be installed,
calibrated, and maintained to ensure accuracy. The meter shall be calibrated
annually. Modifications to the flow metering equipment shall be approved by the
Town of Benson prior to installation. If a required flow measurement device fails,
the Town of Benson shall be notified within 24 hours.
4. Certified Laboratory Analysis
Pollutant analysis shall be performed by a North Carolina Division of Water
Quality Certified Laboratory that is certified in the analysis of the pollutant in
wastewater.
13

Appendix 3.2 — Four Oaks / Benson Interconnector and Town of Benson 0.4 mgd
WWTP Expansion Inter -Local Agreement

FOUR OAKS/BENSON INTERCONNECTOR AND TOWN OF BENSON
0.4 MGD WWTP EXPANSION INTER -LOCAL AGREEMENT
THIS AGREEMENT (the "Agreement"is entered into as of the F
� t �' day of May
2005 by and between Johnston County, the Town of Benson and the Town of Clayton,
North Carolina.
WITNESSETH
WHEREAS the Town of Clayton has purchased treatment capacity in the Johnston
County Central Wastewater Treatment Plant (WWTP) and has the need for an additional
treatment capacity allocation; and
WHEREAS Johnston County's expanded WWTP will be allocated at 80% of its capacity
when it comes on line in May of 2005, and the County must initiate further expansion of
its wastewater treatment capacity; and
WHEREAS the Town of Benson's wastewater treatment facility currently has surplus
treatment capacity and the Town intends to construct additional capacity, and that it will
allow Johnston County to purchase 0.150 mgd if Johnston County wastewater
transmission facilities are extended to the Town of Benson's wastewater treatment plant;
and
WHEREAS the Town of Benson will permit the County's initial temporary capacity
purchase to become permanent and desires to sell additional permanent treatment
allocations when its WWTP is expanded; and
WHEREAS Johnston County has received a $500,000 North Carolina Rural Center
Economic Incentive Grant to construct a Four Oaks to Benson wastewater force main
interconnector that will allow Johnston County to transport wastewater to the Town of
Benson's WWTP for treatment; and
WHEREAS the Town of Benson has received a $425,000 North Carolina Rural Center
Economic Incentive Grant to increase its WWTP capacity by 0.4 mgd to allow Johnston
County to purchase a permanent treatment capacity allocation in the expanded facility.
NOW, THEREFORE, in consideration of the mutual covenants and promises set forth
herein; Johnston County, the Town of Benson and the Town of Clayton hereby agree as
follow:
Page 1 of 4

ARTICLE 1 "THERMS OF AGREEMENT AND TERMINATION
1. The Town of Clayton will purchase a permanent wastewater allocation of
0.150 mgd from Johnston County for a capacity fee of $900,000, and Johnston
County will allocate a capacity of 0.150 mgd in its WWTP for use by the
Town of Clayton.
2. Johnston County will design and construct the Four Oaks to Benson
wastewater force main and complete necessary pumping improvements. The
estimated cost of the project is $1,200,000.
3_ The Town of Benson will design and construct a 0.4 mgd WWTP expansion.
4. The Town of Benson will allocate a capacity of 0.150 mgd in its WWTP for
use by Johnston County. The commodity cost for treatment shall be equal to
the bulk wastewater treatment fee Johnston County charges the Town of
Clayton and its other bulk customers. The commodity cost is subject to
upward adjustment annually. The current bulk commodity fee charged by the
County is $2.15 per 1,000 gallons.
5. Johnston County will pay the Town of Benson a fee in the amount of
$300,000 for the 150,000 gpd wastewater allocation. Johnston County will
pay a fee of $125,000 as a deposit against a future wastewater capacity
allocation.
6. The Town of Benson will sell additional capacity to Johnston County in the
future. The Town agrees to sell at least 150,000 gpd. The unit value (cost per
gpd) of the future wastewater allocation shall be negotiated between the Town
of Benson and the County within limits of the then current actual capital costs
for wastewater plant expansions by the respective parties.
7. Assignment. This Agreement shall insure to the benefit of and be binding
upon the parties hereto and their respective heirs, executors, administrators,
Iegal representatives and successors. Neither party may assign this
Agreement, or any of its rights or obligations hereunder, without the prior
written consent of the other party and any such attempted assignment shall be
void, except that either party may assign this Agreement and/or any of its
rights and/or obligations hereunder, without the other party's consent, upon
written notice to the other party, to any company that acquires all, or
substantially all, of the assets of the party seeking to make the assignment.
8. Notices. When written notice is required by this Agreement, it shall be
considered as served when delivered in person or sent by U.S. first-class mail
to the respective representative of the parties at the following addresses, or
such subsequent addresses for which notice is given pursuant to this Article:
Pave 2of4

TC) TI-LE COUNTY:
Johnston County
Attn: Rick J. Hester
P.O. Box 1049
Smithfield, N.C. 27577
TO THE TOWN OF BENSON:
Town of Benson
Attn: Keith Langdon
P.O. Box 69
Benson, N.C. 27504
TO THE TOWN OF CLAYTON:
Town of Clayton
Attn: Steve Biggs
P.O. Box 879
Clayton, N.C. 27520
9. Modification, Amendment, Supplement or Waiver. No modification,
amendment, supplement to or waiver of this Agreement or any of its
provisions shall be binding upon the parties hereto unless made in wriiing and
duly signed by authorized representatives of both parties.
10. Severability. In the event any one or more of the provisions of the Agreement
shall for any reason be held to be invalid, illegal or unenforceable, the
remaining provisions of this Agreement shall be unimpaired, and the invalid,
illegal or unenforceable provision shaII be replaced by a mutually acceptable
provision, which being valid, legal, and enforceable comes closest to the
intention of the parties underlying the invalid, illegal, or unenforceable
provision,
11. Entirety of the Agreement. This Agreement constitutes the entire Agreement
between the parties and supersedes all previous agreements included promises
and representation, whether written or oral, between the parties with respect to
the subjection matter hereof.
Page 3 of 4

IN WITNESS WIINRF(.)F, the parties hereto, each acting under due and proper
authority, have execut .. this Agreement as of the clay, month, and year first above
written. This is the 1 day of-4,iy2005.
AttLst:
1
jLA(a 1a
Devai-lolt, Deputy Clerk to the
Board of Commissioners
Attest:
Connie Sorrell
Benson Town Clerk
Attest_
Sherry Scog
Clayton Town Clerk
JOHNSTON COUNTY
Honorable Cookie Pope, Chairman
Johnston County Board of Commissioners
TOWN OF BENSON
Honorable Do aid H. Johnson, Mayor
Manager
TO 1 F CLAYTON
4_
6 a
Honorable Jody McLeod, Mayor
Maner
Page 4 of 4

Appendix 4.1 — Existing WWTP Design Data

DESIGN DATA OF BENSON WASTE TREATMENT PLANT
Design Year
Design Population
Design Flows, mgd
Average daily flow
Peak hydraulic flow
Design Waste Loadings, lb/day
BODS (Bio-Chemical Oxygen Demand, 5 day 20° C)
TSS (Total Suspended Solids)
NH3-N (Ammonia Nitrogen)
Phophorous
2008
3,924
1.5
3.75
2,500 (200 mg/L)
2,500 (200 mg/L)
250 (20 mg/L)
100 (8 mg/L)
Bar Screens
Mechanical
Number of units
Design flows, ADF, mgd
PDF, mgd
Channel width, ft
Channel depth, ft
Motor horsepower, hp
Unit power control
Maximum rake lift capacity, lb
Manual
Number of units
Channel width, ft
Channel depth, ft
Unit capacity, mgd
1
1.50
3.75
2
5
0.5
Time Clock
462.0
1
1.5
2
1.65
Grit Chamber
Number of units
Length, ft
Width, ft
Average water depth, ft
Detention time at peak flow, min
Velocity at peak flow, ft/sec
Surface overflow rate at peak flow, mgd/sq ft
Method of grit removal
1
17
1.25
1.50
0.30
1.36
0.077
Mechanical
Comminutor
Number of units
Unit size, in
Unit capacity, mgd
Size of drive unit, hp
1
15
2.4
0.75

Parshall Flume (for flow measuring)
Number of units, 9-inch size 1
Aeration Tanks (Oxidation Ditches)
Number of units 3
Liquid depth, ft 5
Unit Volume, mil gal 0.567
Total Volume, mil gal 1.701
Detention time, average hr 27
BOD5 to aeration tanks, lb/day, average 2,500
Organic loadings to tanks, lb BOD5/1000 ft3, average 11
MLVSS concentration, mg/L 2,200
F/M ratio, lb BOD5/lb MLVSS 0.08
MCRT or SRT, days (@ 10° C, Yn=0.65, BODR=98%) 24
Sludge recycle ratio 1:1
Aeration Facilities for Aeration Tanks
Type of aeration Mechanical, brush type
27 z - in x 10 ft long brush
Number of aerators,
rotor with 7.5 hp drive unit, each/tank 4
Total number of brush aerators 12
Total horsepower provided, hp 90
Aerator capacity at 6-in immersion, lb 02/hr/ft of rotor 1.74
Total aeration capacity, lb 02/hr 208.80
Total oxygenation capacity, lb 02/lb BODr, average 2.00
Total number of 4-hp mixers: Oxidation Ditch No. 1 2
Oxidation Ditch No. 2 4
Oxidation Ditch No. 3 2
Internal (Nitrate) Recycle Pumps
Number of pumps, submersible, horizontal propeller type 2
Pump capacity, gpm, at 855 rpm (variable) and 1 ft. TDH 2,800
Drive horsepower, hp 2
Secondary Clarifiers
Number of units, 35 ft diam x 10 ft SWD 2
Unit Volume, gal 71,930
Number of units, 35 ft diam x 12 ft SWD 2
Unit Volume, gal 86,315
Total Volume, gal 316,490
Detention time at average flow, hrs 5.06
Unit surface area, sq ft 962
Total surface area, sq ft 3,848
Surface overflow rate, gpd/sq ft 390
Unit weir length, ft 110
Total weir length, ft 440

Weir overflow rate, gpd/lf 3,410
Type of sludge removal Pump
Filters
Number of filters, 10 ft x 12 ft 5
Total surface area, sq ft 600
Filtration rate at average daily flow, gpm/sq ft 1.74
Filtration rate at peak daily flow, gpm/sq ft 4.34
Maximum wash rate at 20° C, gpm/sq ft 15.0
Filter Media
Anthracite Medium - 2 ft 3 inch depth of the media. Particle sizes ranging
from 1.2 mm to 1.6 mm, with a maximum uniformity
coefficient of 1.4 and not more than 10% by weight being no
more than 1.2 mm. Anthracite has a specific gravity of 1.57.
Silica Medium 12-inch depth of the media. Particle sizes ranging from 0.50
mm, with a maximum uniformity coefficient of 1.6 and not
more than 10% by weight being smaller than 0.50 mm. the
specific gravity of sand is 2.50.
Gravel 13-inch depth of the media consisting of:
4-inch 1/8" x No. 16 mesh
3-inch 1/8" x 3/8"
3-inch 3/8" x 1"
3-inch 5/8" x 1"
Underdrain system Wheeler bottom type
Lime Feed System (for alkalinity and pH Control)
Total lime storage capacity, cu ft 1,800
Number of feed pumps 2
Feed rate, gal/hr 0 - 0.5
Alum Feed System (for phosphorus removal)
Number of storage tanks, 12'-0" ID x 18'-6" 2
Unit capacity, gal 15,000
Total capacity, gal 30,000
Number of feed pumps 2
Feed rate, gal/hr at 150 psig back pressure 50
Motor horsepower, hp 1
Chlorination System
Chlorine Contact Tanks
Number of tanks 23'-6" x 8' - 8" x 6' - 6" SWD 2
Unit volume, gal 8,593.5
Total volume, gal 17,187
Detention time at average daily flow, min. 16.5

Chlorine Feed System
Number of chlorinators 2
Chlorine feed rate, lb/day 20 - 200
Number of one ton cylinders 4
Filter Backwash Clear Water Storage
Number of tanks - 18'-8" x 18'-0" x 6'-6"/11'-3" x 9'-10" x 5'-0"
Total volume, gal
1
20,475
Post Aeration
Number of units 18'-6" x 18'-0" x 6'-6" 1
Total volume, gal 16,190
Detention time at average daily flow, min. 15.5
Type of aeration Submerged self -aspirating type
Number of aerators, 7.5 hp 1
Aerator capacity, CWTR at 41 cfm air flow and STP in lb 02/hr 26
Dechlorination System
Solution type Sodium sulfite
Number of metering pumps 2
Capacity, gph 0 to 1.5
Solution tank size, gal 250
Aerated Sludge Holding Lagoon (for sludge stabilization, disposal)
Number of lagoons 1
Size of lagoon
Area at water surface, sq ft 191 ft x 299 ft = 57,110
Area at bottom surface, sq ft 166 ft x 274 ft = 45,310
Side slopes 1.5:1
Liquid depth, ft 8.5
Total volume, gal 3,080,220
Stabilization Lagoons (for equalization of influent flow & filter backwash waste)
Number of lagoons 2
Size of lagoon Larger Lagoon Smaller lagoon
Area at water surface 315' x 575' = 181,125 sq ft. 1/2 (385+265)x795=258,375 sq ft
Area at bottom 300' x 560' = 168,000 sq ft 1/2 (370+250)x780=241,800 sq ft
Slide Slopes 2.5:1
Liquid depth 3.0 ft
Volume of each lagoon, gal 3,844,800 5,611,960
Total volume, gal 9,456,760

Pumps
No.
hpleach unit
TDH
Design Capacity*
Screw Pumps
2
3
7 ft
1,370 gpm
Screw Pumps
1
5
7 ft
1,750 gym
Sludge Recirculation Pumps
2
10
17 ft
1,050 gpm
Sludge Waste Pumps
1
1.5
10 ft
100 gpm
Scum Pumps
2
1.5
10 ft
100 gpm
Filter Lift Pumps
3
15
34 ft
1,300 gpm
Filter Backwash Pumps
2
40
40 ft
2,700 gpm
Surface Wash Pumps
2
10
198 ft
120 gpm
Wash Water Pumps
2
5
150 ft
75 gpm
Sludge Lagoon Pumps
2
5.4
25 ft
200 gpm
* For Each Pump1,750 gpm

Appendix 4.2 — Sludge Management Plan and Residuals Land Application Permit

Sludge Management Plan
Benson Wastewater Treatment Plant
NPDES Permit No. NC0020389
Non -Discharge Permit No. WQ0012514
The Town of Benson operates a 1.5 mgd modified biological nutrient removal (BNR) plant
which discharges its effluent into Hannah Creek in the Neuse River Basin under NPDES Permit
No. NC0020389. Waste sludge from the modified BNR plant is discharged to the existing
3,247,000 gallon capacity aerated basin for long-term sludge stabilization and storage.
Periodically, the sludge is allowed to settle in the basin and the supernatant is withdrawn and
recycled back to the plant headworks for reprocessing. The stabilized sludge which meets pollutant
limits and Class B pathogen reduction and vector attraction reduction requirements is later disposed
of in accordance with Non -Discharge Permit No. WQ0012514.
The Class B pathogen reduction requirements are met using either Alternative 1 [Monitoring of
Fecal Coliform, 503.32(b)(2)] or Alternative 2 [Use of PSRP, 503.32(b)(3)]. The vector attraction
reduction requirements are met using Option 3 [503.33(b)(3)], Option 6 [503.33(b)(6)], Option 9
[503.33(b)(9)], or Option 10 [503.33(b)(10)].

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P E., Director
Coleen H. Sullins, Deputy Director
Division of Water Quality
February 27, 2004
MR. KEITH R. LANGDON, TOWN MANAGER
TOWN OF BENSON
303 EAST CHURCH STREET
BENSON, NORTH CAROLINA 27504
Subject: Attachment B Certification
Permit No. WQ0012514
Town of Benson
Town of Benson Residuals
Land Application Program
Land Application of Residual Solids
Johnston County
Dear Mr. Johnson:
In accordance with the minor modification request that was received from you on October 16,
2003, we are forwarding herewith a modified Attachment B, certified February 27, 2004, to the Town of
Benson for the subject residuals land application program.
This certification is being issued to modify Attachment B to remove Site Nos. JD-01, JD-03, and
JD-04 from the list of sites that are approved to receive residuals under this residuals land application
program. These sites are all owned by Mr. James L. Draughon, Jr., are all located in Sampson County,
contained 39.60 acres of application area, and are currently being considered by the Division of Water
Quality (Division) for approval under the Town of Clayton Residuals Land Application Program (i.e.,
Application No. WQ0023178).
The Town still has one 18.20-net acre land application site permitted under this program. It does
appear that, from a plant available nitrogen (PAN) standpoint, this single site is sufficient to manage the
Town's maximum annual residuals generation rate of 250 dry tons per year adequately. The Division
does, however, want to caution the Town that the PAN concentration of the residuals may not be the
limiting factor affecting land application rates. Rather other residuals qualities such as water content may
also affect how much residuals per acre may be land applied during a period of time. In addition, the
remaining site is seasonally restricted such that the Town may only conduct land application events
during the months of April through November, inclusive. Therefore, the Town may want to take this
opportunity to evaluate its program to ensure that it has the capacity, diversity, and flexibility needed in
order to ensure proper residuals management.
Please replace the existing Attachment B of Permit No. WQ0012514 that was previously
certified on September 27, 2002, with this modified Attachment B. Note that only the vicinity and
buffer maps for any new and modified land application sites are attached to this modified Attachment B.
It is the Permittee's responsibility to ensure that a complete permit is created by inserting this modified
Attachment B and vicinity and buffer maps into Permit No. WQ0012514, issued on September 27, 2002,
and making sure to retain any vicinity and buffer maps for any existing and unmodified land application
sites. ex,TA
tot
NCt)Ei•l;r{
Non -Discharge Permitting Unit Internet http://h2o.enr.state.nc.us/ndpu
1617 Mail Service Center, Raleigh, NC 27699-1617 Telephone [phone] Fax [phone]
DENR Customer Service Center
An Equal Opportunity Action Employer
Telephone [phone]
50% recycled/10% post -consumer paper

Mr. Don H. Johnson
February 27, 2004
Page 2
This modified Attachment B shall be effective from the date of certification; shall void
Attachment B of Permit No. WQ0012514 that was previously certified on September 27, 2002; and shall
be subject to the conditions and limitations as specified therein and well as those specified in the above -
referenced permit. As always, remember to take the time to review this modified Attachment B
thoroughly, as some of the conditions contained therein may have been changed since the last
certification. Note that this modified Attachment B is hereby incorporated by reference into Permit No.
WQ0012514, issued on September 27, 2002.
If any parts, requirements, and/or limitations contained in this certification or modified Attachment B are
unacceptable, you have the right to request an adjudicatory hearing upon, written request within 30 days
following receipt of the certification. This request shall be in the from of a written petition, conforming to
Chapter 150B of the North Carolina General Statutes and filed with the Office of Administrative Hearings
at 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such demands are made, this
permit shall be final and binding.
If you need any additional information concerning this matter, please contact Ms. Shannon Mohr
Thornburg by telephone at [phone], extension 353, or via e-mail at
[e-mail].
Alan W. Klimek, P.E.
cc: Mr. Scott D. Berg, Engineering Consulting Services, Ltd.
Mr. A. Davis Benton, Atlantic Coast Contracting, Inc.
Johnston County Health Department
Sampson County Health Department
Raleigh Regional Office -Water Quality Section
Fayetteville Regional Office -Water Quality Section
Fayetteville Regional Office -Groundwater Section
Central Office -Groundwater Section
Non -Discharge Compliance/Enforcement Unit
Water Quality Central Files
NDPU Files
NDPU Residuals Program Coordinator

ATTACHMENT B - A
d
a
Lessee/Operator
Landowner
Site/Field ID
ry N
n 00
ny
0
N
CO
m
vi
vi
m
Certification Date: February 27, 2004
Permit No. WQ0012514

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E.., Director
Division of Water Quality
September 27, 2002
MR. DON H. JOHNSON, MAYOR
TOWN OF BENSON
303 EAST CHURCH STREET
BENSON, NC 27504
Subject: Permit No. WQ0012514
Town of Benson
Town of Benson Residuals Land
Application Program
Land Application of Residual Solids (503)
Johnston County
Dear Mr. Johnson:
In accordance with your permit modification and renewal application package received on May
10, 2002 as well as the additional information received on June 27, 2002, we are forwarding herewith a
modified and renewed Permit No. WQ0012514 dated September 27, 2002, to the Town of Benson for the
subject residuals land application program.
This permit shall be effective from the date of issuance until August 31, 2007; shall void Permit
No. WQ0012514, issued on October 24, 1996; and shall be subject to the conditions and limitations as
specified therein. Make note of this permit's expiration date and the fact that a permit renewal
application is due to the Division of Water Quality (Division) no later than six months prior to that date
(Le., see Condition VI. 7.), as the Division does not send reminders to apply for permit renewal.
This permit is being issued to delete 406.6 acres permitted in the previous issuance of this permit,
to add four new land application sites (totaling 57.8 acres) in Sampson County, and to approves the
continued operation of the residuals Iand application program for another five-year cycle. As always,
remember to take the time to review this permit thoroughly, as some of the conditions contained
therein may have been added, changed, or deleted since the Iast issuance. Pay particular attention to the
monitoring requirements in this permit. Failure to establish an adequate system for collecting and
maintaining the required operational information will result in future compliance problems.
If any parts, requirements, and/or limitations contained in this permit are unacceptable, you have
the right to request an adjudicatory hearing upon written request within 30 days following receipt of this
permit. This request shall be in the from of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes and filed with the Office of Administrative Hearings at 6714 Mail Service
Center, Raleigh, North Carolina 27699-6714. Unless such demands are made, this permit shall be final
and binding.
Non -Discharge Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
DENR Customer Service Center
An Equal Opportunity Action Employer
NCOENR
Internet http://h2o.enr.state.nc.us/ndpu
Telephone [phone] Fax [phone]
Telephone [phone]
50% recycled/10% post -consumer paper

If you need any additional information concerning this matter, please contact Mr. J. R. Joshi by
telephone at [phone], extension 363, or via e-mail at [e-mail].
cc: Mr. Scott D. Berg, ECS, Ltd.
Mr. Davis Benton, Atlantic Coast Contracting, Inc.
Sampson Health Department
Johnston Health Department
Raleigh Regional Office -Water Quality Section
Fayetteville Regional Office -Water Quality Section
Raleigh Regional Office -Groundwater Section
Fayetteville Regional Office -Groundwater Section
Central Office -Groundwater Section
Technical Assistance and Certification Unit
Non -Discharge Compliance/Enforcement Unit
Water Quality Central Files
NDPU Files
NDPU Residuals Program Coordinator
OCT — 7 2002
Sincerely,
Alan W. Klimek, F.E.
2

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
LAND APPLICATION OF RESIDUAL SOLIDS (503) PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Town of Benson
Johnston County
FOR THE
continued operation of a residuals land application program for the Town of Benson and consisting of the
land application of residuals generated by the residuals source -generating facilities listed in the most
recently -certified Attachment A to the land application sites listed in the most recently -certified
Attachment B with no discharge of wastes to surface waters, pursuant to the permit modification and
renewed application package received on May 10, 2002 as well as the additional information received on
June 27, 2002; and in conformity with the project plan, specifications, and other supporting data
subsequently filed and approved by the Department of Environment and Natural Resources and considered
a part of this permit.
This permit shall be effective from the date of issuance until August 31, 2007; shall void Permit
No. WQ0012514, issued on October 24, 1996; and shall be subject to the following specified conditions
and limitations:
I. PERFORMANCE STANDARDS
1. The residuals land application program shall be effectively maintained and operated as a non -
discharge system to prevent the discharge of any wastes resulting from the operation of this
program.
2. This permit shall become voidable if the soils of the land application sites fail to assimilate the
residuals adequately and may be rescinded unless the land application sites are maintained and
operated in a manner that will protect the assigned water quality standards of the surface
waters and groundwater.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface waters or groundwater resulting from the operation of this residuals land application
program.
1

4. In the event that the residuals land application program is not operated satisfactorily, including
the creation of nuisance conditions, the Permittee shall cease land applying residuals to the
site, contact the Water Quality Section of the appropriate Division of Water Quality's
(Division) regional office, and take any immediate corrective actions as may be required by
the Division.
5. No residuals other than those generated by the residuals source -generating facilities listed in
the most recently -certified Attachment A of this permit shall be approved for land application
in accordance with this permit.
6. The pollutant concentrations in any residuals that are land applied to any land application site
shall not exceed the following Ceiling Concentrations (i.e., dry weight basis):
Parameter
Ceiling Concentration
(milligrams per kilogram)
Arsenic
75
Cadmium
85
Copper
4,300
Lead
840
Mercury
57
Molybdenum
75
Nickel
420
Selenium
100
Zinc
7,500
7. When residuals are land applied under the conditions of this permit, the Class A pathogen
requirements and site restrictions in 40 CFR Part 503.32(a) or the Class B pathogen
requirements and site restrictions in 40 CFR Part 503.32(b), and one of vector attraction
reduction requirements in 40 CFR Part 503.33 shall be met. Additionally, an evaluation shall
be performed that demonstrates the residuals' ability to comply with this requirement. Upon
request, a copy of this evaluation, including all test results and calculations, shall be submitted.
Only residuals that are generated by the residuals source -generating facilities that are
identified as being exempt from this condition in the most recently -certified Attachment A
shall not be required to comply with the specified pathogen reduction and vector attraction
reduction requirements.
8. Only the land application sites listed in the most recently -certified Attachment B of this permit
are approved for residuals land application.
9. This permit shall become voidable unless the agreements between the Permittee and the
landowners and lessees or operators of any land application sites listed in the most recently -
certified Attachment B of this permit not owned by the Permittee are in full force and effect.
These agreements shall be considered expired concurrent with the expiration date of the permit
and shall be renewed at the same time the permit is renewed.
10. The appropriate local govemmental official (i.e., county manager, city manager, etc.) shall be
notified at least 24 hours prior to the initial residuals land application event to any new land
application site.-4) addition, the appropriate county manager's office shall be notified prior to
the initial residuals land application event on any new site so that they will be aware that
residuals land application activities have commenced on the site.
R�l{�`.
2

11. The Water Quality Section of the appropriate Division's regional office shall be notified at
least 24 hours prior to the initial residuals land application event on any new land application
site. Such notification to the Regional Water Quality Supervisor shall be made during normal
office hours (i.e., from 8:00 a.m. until 5:00 p.m.) between Monday and Friday, but excluding
State Holidays. A list of the Division's regional offices, their county coverage, and their
contact information may be downloaded from the web site at http://h2o.enr.state.nc.us/ndpu/.
II. OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities and land application sites shall be properly maintained and operated at all times.
2. Upon classification of the residuals land application program by the Water Pollution Control
System Operators Certification Commission (WPCSOCC), the Permittee shall designate a
certified land application/residuals operator to be in responsible charge (ORC) of the program.
The operator shall hold a certificate of the type classification assigned to the program by the
WPCSOCC. The Permittee shall also designate a certified back-up operator of the appropriate
type to comply with the conditions of 15A NCAC 8G .0202.
3. No residuals shall be stored at any land application site at any time, unless written approval
has first been requested and obtained from the Division.
4. A copy of this permit shall be maintained in all manned equipment at the land application sites
when residuals are being land applied during the life of this permit. A spill prevention and
control plan shall be maintained in all residuals transport and application vehicles.
5. When land applying residuals to any land application site, the following buffer zones shall be
maintained at all times:
a. 400 feet from residences or places of public assembly under separate ownership for
surface application methods; however, the buffer zone requirement may be reduced to a
minimum of 100 feet upon written consent of the owner and approval from the Water
Quality Section of the appropriate Division's regional office in Attachment B of this
permit;
b. 200 feet from residences or places of public assembly under separate ownership for
subsurface application methods; however, the buffer zone requirement may be reduced to
a minimum of 100 feet upon written consent of the owner and approval from the Water
Quality Section of the appropriate Division's regional office in Attachment B of this
permit;
c. 100 feet from any public or private water supply source, waters classified as SA or SB,
and any Class I or Class II impounded reservoir used as a source of drinking water for
both methods;
d. 100 feet from any streams classified as WS or B, any other stream, canal, marsh or coastal
waters and any other lake or impoundment for surface application;
e. 50 feet from any streams classified as WS or B, any other stream, canal, marsh or coastal
waters and any other lake or impoundment for subsurface application;
f. 50 feet from property lines for both surface and subsurface application methods;
g. 50 feet from public right of ways for both surface and subsurface application methods;
3

h. 10 feet from upslope interceptor drains and surface water diversions for both surface and
subsurface application methods; and
i. 25 feet from downslope interceptor drains, surface water diversions, groundwater drainage
systems, and surface drainage ditches for both surface and subsurface application methods.
Some of the buffers specified above may not have been included in previous permits for this
residuals land application program. However, any land application sites that are listed in the
most recently -certified Attachment B of this permit, but were approved with different buffers
shall be reflagged to comply with these buffers.
Maximum slope for land application of residuals shall be 10 percent for surface application
methods and 18 percent for subsurface application methods.
7. Specific residuals land application area boundaries shall be clearly marked on each land
application site prior to and during a residuals land application event.
8. The metal loading rates on any land application site shall not exceed the following
Cumulative Pollutant Loading Rates (CPLRs):
Parameter
CPLR
(kilograms per hectare)
CPLR
(pounds per acre)
Arsenic
41
36
Cadmium
39
34
Copper
1,500
1,338
Lead
300
267
Mercury
17
15
Molybdenum
n/a
n/a
Nickel
420
374
Selenium
100
89
Zinc
2,800
2,498
9. An acceptable pH shall be maintained in the soil, residuals, and lime mixture, greater than 6.0,
on all land application sites onto which residuals are land applied to ensure optimum yield for
the crops specified in Condition H. 13. The agronomist shall provide information on the pH
best suited for the specified crop and the soil type.
10. Should any of the residuals generated by the residuals source -generating facilities listed in the
most recently -certified Attachment A of this permit contain a high salt content (i.e., high
sodium adsorption ratio (SAR) of five or higher), the exchangeable sodium percentage (ESP)
or other method as approved by the Division, using the results from the annual soils analysis
as required by this permit, shall be monitored on all of the land application sites. The local
Cooperative Extension Office, the Department of Agriculture and Consumer Services, the
Natural Resource Conservation Service, a North Carolina -licensed Soil Scientist, or other
agronomist shall review the results and make recommendations regarding soil amendments
(e.g., gypsum, etc.) or other ameliorative mechanism for maintaining the integrity of the site in
terms of suitability for land application of residuals and maintaining conditions conducive to
crop growth. The Perrnittee shall implement such recommendations accordingly and shall
maintain written records of each monitoring event that includes details of the sites covered and
rate of soil amendment application.
fC,T
2007:
4

11. Prior to land applying residuals to any land application site that has previously received or is
intended to receive animal waste (e.g., poultry litter, etc.) or other source of nutrients (e.g.,
fertilizer, etc.) in the future, the Permittee shall obtain information pertaining to the volume
and analysis of the applied waste/nutrients from the landowner and/or lessee/operator of the
site. The Permittee shall be responsible for verifying the volume of residuals that may be land
applied to the site such that the plant available nitrogen (PAN) loading rate for the specified
crop (i.e., see Condition II. 13.) shall not be exceeded by all of the sources of PAN applied.
Should the maximum PAN loading rate be met or exceeded, then no additional residuals shall
be land applied to the site.
12. A suitable vegetative cover, as listed in Condition II. 13., shall be maintained on land
application sites onto which residuals are land applied in accordance with the crop
management plan outlined by the local Cooperative Extension Office, the Department of
Agriculture and Consumer Services, the Natural Resource Conservation Service, or other
agronomist and as approved by the Division.
13. Residuals and other sources of PAN shall be land applied to all land application sites at
agronomic rates in accordance with the crop management plan outlined by the local
Cooperative Extension Office, the North Carolina Department of Agriculture and Consumer
Services, the Natural Resource Conservation Service, or other agronomist. Under no
circumstances shall the following PAN loading rates land applied to any site exceed the
following for the specified crops:
Crop
PAN
(pounds per
acre peryear)
Crop
PAN
(pounds per
acre per year)
Alfalfa
200
Forest
(Hardwood or Softwood)
75
Bermuda Grass
(Hay or Pasture)
220
Milo
100
Blue Grass
120
Small Grain
(Wheat, Barley, or Oats)
100
Corn
(Grain)
160
Sorghum or Sudex
(Pasture)
180
Corn
(Silage)
200
Sorghum or Sudex
(Silage)
220
Cotton
70
Soybeans
200
Fescue
250
Timothy, Orchard, or
Rye Grasses
200
The Permittee shall apply for and receive a modification of this permit before land applying
residuals on any land application site that is to be established in a crop other than those listed
above. A maximum PAN loading rate for the desired crop shall be approved with the permit
modification.
5

If the land application sites are to be overseeded (e.g., bermuda grass in the summer and rye
grass in the winter with BOTH crops to receive residuals), then the second crop shall receive
an application of PAN at a rate of no greater than 50 pounds per acre per year. This practice
shall be allowed as long as the second crop is to be harvested. If the second crop is to be
planted for erosion control only and is to be tilled into the soil, then no residuals shall be land
applied to these sites because the PAN will essentially be returned to the soil.
Residuals shall not be land applied at rates greater than agronomic rates, unless authorized by
the Division.
14. Animals shall not be grazed on any land application site for 30 days after any residuals land
application event. Sites that are to be used for grazing shall have fencing that will be used to
prevent access after each event.
15. Food crops, feed crops, and fiber crops that do not come in contact with the residuals shall not
be harvested for 30 days after any residuals land application event.
16. Food crops with harvested parts that touch the residual/soil mixture and are totally above the
land surface (e.g., tobacco, melons, cucumbers, squash, etc.) shall not be harvested for 14
months after any residuals land application event.
17. Food crops with harvested parts below the surface of the land (i.e., root crops such as potatoes,
carrots, radishes, etc.) shall not be harvested for 20 months after any residuals land application
event when the residuals remain on the land surface for four months or longer prior to
incorporation into the soil.
18. Food crops with harvested parts below the surface of the land shall not be harvested for 38
months after any residuals land application event when the residuals remain on the land
surface for Less than four months prior to incorporation into the soil.
19. Turf shall not be harvested for. one year after any residuals land application event.
20. Adequate provisions shall be taken to prevent wind erosion and surface runoff from conveying
residuals from the land application sites onto adjacent properties or into any surface waters.
21. Adequate procedures shall be provided to prevent surface runoff from carrying any land
applied or stored residuals into any surface waters.
22. Surface -applied residuals shall be plowed or disced within 24 hours after land application on
land application sites with no cover crop established.
23. For land application sites that are prone to flooding or within the 100-year flood elevation,
residuals shall be land applied only during periods of dry weather. The residuals shall be
incorporated into the soil within 24 hours after land application.
24. Residuals shall not be land applied during inclement weather or until 24 hours following a
rainfall event of 0.5-inch or greater in 24 hours. Any emergency residuals land application
measures shall first be approved in writing by the Division.
25. Residuals shall not be- land ,applied to any land application site that is flooded, frozen, or
snow-covered.
b

26. Appropriate measures shall be taken to control public access to the land application sites
during active site use and for the 12-month period following the last residuals land application
event. Such controls may include the posting of signs indicating the activities being
conducted at each site.
III. MONITORING AND REPORTING REQUIREMENTS
1. Any monitoring (i.e., including groundwater, surface water, residuals, soil, or plant tissue
analyses) deemed necessary by the Division to ensure protection of the environment shall be
established, and an acceptable sampling and reporting schedule shall be followed.
2. Residuals generated by each residuals source -generating facility listed in the most -recently -
certified Attachment A of this permit shall be analyzed to demonstrate that they are non-
hazardous under the Resource Conservation and Recovery Act (RCRA). A corrosivity,
ignitability, and reactivity analysis as well as a Toxicity Characteristics Leaching Procedure
(TCLP) analysis shall be conducted on residuals generated by each residuals source -
generating facility listed in the most recently -certified Attachment A of this permit. The
analyses shall be performed at the frequency specified in the most recently -certified
Attachment A of this permit, and the results shall be maintained on file by the Permittee for a
minimum of five years. If residuals generated by a particular residuals source -generating
facility are land applied at a frequency less than that which is specified in the most recently -
certified Attachment A of this permit, the analyses shall be required for each residuals land
application event. Only residuals that are generated by the residuals source -generating
facilities that are identified as being exempt from this condition in the most recently -certified
Attachment A of this permit shall not be required to comply with this monitoring requirement.
The TCLP analysis shall include the following parameters (i.e., note the regulatory level in
milligrams per liter in parentheses):
Arsenic (5.0)
Barium (100.0)
Benzene (0.5)
Cadmium (1.0)
Carbon tetrachloride (0.5)
Chlordane (0.03)
Chlorobenzene (100.0)
Chloroform (6.0)
Chromium (5.0)
m-Cresol (200.0)
o-Cresol (200.0)
p-Cresol (200.0)
Cresol (200.0)
2,4-D (10.0)
1,4-Dichlorobenzene (7.5)
1,2-Dichloroethane (0.5)
1,1-Dichloroethyiene (0.7)
2,4-Dinitrotoluene (0.13)
Endrin (0.02)
Hex achlorobenzene (0.13)
Heptachlor (arid its hydroxide) (0.008)
Hex achl oro-1, 3-bu tadiene (0.5)
Hexachloroethane (3.0)
Lead (5.0)
Lindane (0.4)
Mercury (0.2)
Methoxychlor (10.0)
Methyl ethyl ketone (200.0)
Nitrobenzene (2.0)
Pentachlorophenol (100.0)
Pyridine (5.0)
Selenium (1.0)
Silver (5.0)
Tetrachloroethylene (0.7)
Toxaphene (0.5)
Trichloroethylene (0.5)
2,4,5-Trichlorophenol (400.0)
2,4,6-Trichlorophenol (2.0)
2,4,5-TP (Silvex) (1.0)
Vinyl chloride (0.2)
After the residuals have been monitored as specified above for two years at the frequency
specified in the most recently -certified Attachment A of this permit, the Permittee may submit
a request to the Division for a permit modification to request a reduction of this monitoring
requirement. In no case, however, shall the frequency of monitoring be less than once per
permit cycle.
7

An analysis shall be conducted on residuals generated by each residuals source -generating
facility listed in the most, recently -certified Attachment A of this permit. The analysis shall be
performed at the frequency specified in the most recently -certified Attachment A of this
permit, and the results shall be maintained on file by the Permittee for a minimum of five
years. If residuals generated by a particular residuals source -generating facility are land
applied at a frequency less than that which is specified in the most recently -certified
Attachment A of this permit, an analysis shall be required for each residuals land application
event. The analysis shall include, but shall not necessarily be limited to, the following
parameters:
Aluminum
Ammonia -Nitrogen
Arsenic
Cadmium
Calcium
Copper
Lead
Magnesium
Mercury
Molybdenum
Nickel
Nitrate -Nitrite Nitrogen
Percent Total Solids
pH
Phosphorus
Potassium
Selenium
Sodium
Total Kjeldahl Nitrogen
Zinc
Plant Available Nitrogen
(by calculation)
After the residuals generated by a particular residuals source -generating facility have been
monitored for two years at the frequency specified in the most recently -certified Attachment A
of this permit, the Permittee may submit a request to the Division for a permit modification to
reduce the frequency of this monitoring requirement. In no case, however, shall the frequency
of this monitoring be less than once per year when a residuals land application event of
residuals generated by the residuals source -generating facility occurs during that year.
4. Residuals generated by each residuals source -generating facility listed in the most recently -
certified Attachment A of this permit shall be monitored for compliance with Condition I. 7.
The monitoring shall be performed at the frequency specified in the most recently -certified
Attachment A of this permit, and data to verify pathogen and vector attraction reduction of the
residuals shall be maintained on file by the Permittee for a minimum of five years. The
required data shall be specific to the stabilization process utilized, but also shall be sufficient
to demonstrate clear compliance with the Class A pathogen reduction requirements in 40 CFR
Part 503.32(a) or the Class B pathogen reduction requirements and site restrictions in 40 CFR
Part 503.32(b) as well as one of vector attraction reduction requirements in 40 CFR Part
503.33. In addition, the Environmental Protection Agency (EPA) certification statements
concerning compliance with pathogen reduction requirements, vector attraction reduction
requirements, and management practices shall be completed quarterly by the proper authority
or authorities, if more than one is involved (i.e., either the person who prepares the residuals,
the person who derives the material, or the person who applies the residuals). Only residuals
that are generated by the residuals source -generating facilities that are identified as being
exempt from Condition I. 7. in the most recently -certified Attachment A of this permit shall
not be required to comply with this monitoring requirement.
5. Laboratory analyses as required by Condition III. 2., Condition III. 3., and Condition III. 4.
shall be performed/gathered on the residuals as they are to be land applied. Furthermore,
analytical determinations made pursuant to the monitoring and reporting requirements of this
permit shall be made by a laboratory certified by the Division for the required parameter(s)
under 15A NCAC 2H .0800 or-15A,NCAC-2H.-.1100. .
OCT 2007

Proper records shall be maintained by the Permittee tracking all residuals land application
events. These records shall include, but are not necessarily limited to, the following
information:
a. Source of residuals;
b. Date of land application;
c. Location of land application (i.e., site, field, or zone number);
d. Method of land application;
e. Weather conditions (i.e., sunny, cloudy, raining, etc.);
f. Soil conditions (i.e., dry, wet, frozen, etc.);
g.
Type of crop or crops to be grown on field;
h. Volume of residuals land applied in gallons per acre, dry tons per acre, or kilograms per
hectare;
i. Volume of animal waste or other nutrient source applied in gallons per acre, dry ton per
acre, or kilograms per hectare (if applicable);
Volume of soil amendments (i.e., lime, gypsum, etc.) applied in gallons per acre, dry ton
per acre, or kilograms per hectare (if applicable); and
k. Annual and cumulative totals of dry tons per acre of residuals as well as animal waste and
other sources of nutrients (i.e., if applicable), annual and cumulative pounds per acre of
each heavy metal (i.e., shall include, but shall not be limited to, arsenic, copper, lead,
mercury, molybdenum, nickel, selenium, and zinc), annual pounds per acre of PAN, and
annual pounds per acre of phosphorus applied to each field.
J-
A representative annual soils analysis (i.e., Standard Soil Fertility Analysis) shall be
conducted on each land application site on which a residuals land application event in the
respective calendar year has occurred or is to occur, and the results shall be maintained on file
by the Permittee for a minimum of five years. The Standard Soil Fertility Analysis shall
include, but is not necessarily limited to, the following parameters:
Acidity
Calcium
Cation Exchange Capacity
Copper
Base Saturation (by calculation)
Exchangeable Sodium Percentage (by calculation)
Magnesium Phosphorus
Manganese Potassium
Percent Humic Matter Sodium
pH Zinc
8. Three copies of all required monitoring and reporting requirements as specified in Condition
III. 1., Condition III. 2., Condition III. 3., Condition III. 4., Condition III, 5., Condition III, 6.,
and Condition III. 7.(REORDER list, if RCRA monitoring is not required, and VERIFY that
correct conditions are referenced) shall be submitted annually on or before March 1st of the
year following the residuals land application event to the following address:
NCDENR-DWQ
Water Quality Section
Non -Discharge Compliance/Enforcement Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
9

9. Noncompliance Notification:
The Permittee shall report by telephone to the Water Quality Section of the Division's Raleigh
Regional Office at telephone number [phone], as soon as possible, but in no case more
than 24 hours or on the next working day following the occurrence or first knowledge of the
occurrence of any of the following:
a. Any occurrence with the residuals land application program that results in the land
application of significant amounts of residuals that are abnormal in quantity or
characteristic.
b. Any failure of the residuals land application program resulting in a release of material to
receiving waters.
c. Any time that self -monitoring information indicates that the residuals land application
program has gone out of compliance with the conditions and limitations of this permit or
the parameters on which the program system was designed.
d. Any process unit failure, due to known or unknown reasons, that render the residuals land
application program incapable of adequate residuals treatment.
e. Any spillage or discharge from a vehicle or piping system transporting residuals to the
application site.
Persons reporting such occurrences by telephone shall also file a written. report in letter form
within five days following first knowledge of the occurrence. This report shall outline the
actions taken or proposed to be taken to ensure that the problem does not recur.
IV. GROUNDWATER REOUIREMENTS
1. Land Application Site Requirements:
a. Each land application site identified with a GW-A in the most recently -certified
Attachment B of this permit is dominated by soils with a mean seasonal high water table
greater than three feet below the land surface. Residuals land application events may
occur on these sites throughout the year.
b. Each land application site identified with a GW-B in the most recently -certified
Attachment B of this permit is dominated by soils with a mean seasonal high water table
between one and three feet below the land surface. Residual land application events on
these sites shall be prohibited from December through March, inclusive. No residuals
shall be land applied to these sites when the vertical separation between the depth of
residuals land application and the water table is less than three feet. The actual water
table depth for seasonally -restricted soils shall be verified by soil borings within 24 hours
prior to any residuals land application event that occurs from April through November,
inclusive. The number of borings advanced shall be sufficient to characterize water table
conditions across the land application site adequately. Any open borings shall be properly
filled with native soil, prior to the residuals land application event, to decrease the chance
of any residuals contaminating the groundwater.
0 CT
200?
10

2. Applicable Boundary Requirements:
a. The COMPLIANCE BOUNDARY for residuals land application programs is specified by
regulations in 15A NCAC 2L (i.e., "Groundwater Classifications and Standards"). The
Compliance Boundary for each land application site is established at either 250 feet from
the residuals land application area or 50 feet within the property boundary, whichever is
closest to the residuals land application area. An exceedance of Groundwater Quality
Standards at or beyond the Compliance Boundary is subject to immediate remediation
action according to 15A NCAC 2L .0106 (d)(2).
b. The REVIEW BOUNDARY shall be established around each land application site
midway between the Compliance Boundary and the perimeter of the residuals land
application area. Any exceedance of Groundwater Quality Standards at the Review
Boundary shall require action in accordance with 15A NCAC 2L .0106 (d)(2).
3. Additional Requirements:
a. Any groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
V. INSPECTIONS
1. Prior to each residuals land application event, the Permittee or his designee shall inspect the
residuals storage, transport, and application facilities to prevent malfunctions and
deterioration, operator errors, and discharges that may cause or lead to the release of wastes to
the environment, a threat to human health, or a nuisance. The Permittee shall maintain an
inspection log or summary including at least the date and time of inspection, observations
made, and any maintenance, repairs, or corrective actions taken by the Permittee. This log of
inspections shall be maintained by the Permittee for a period of five years from the date of the
inspection and shall be made available to the Division or other permitting authority, upon
request.
Any duly authorized officer, employee, or representative of the Division may, upon
presentation of credentials, enter and inspect any property, premises, or place on or related to
the land application sites or facilities at any reasonable time for the purpose of determining
compliance with this permit; may inspect or copy any records that must be kept under the
terms and conditions of this permit; and may obtain samples of groundwater, surface water, or
leachate.
VI. GENERAL CONDITIONS
1. This permit shall become voidable unless the residuals land application events are carried out
in accordance with the conditions of this permit, the supporting materials, and in the manner
approved by the Division.
2. This permit shall be effective only with respect to the nature and volume of residuals described
in the application and other supporting data.
3. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division in accordance with North Carolina General
Statutes §143-215.6A through §143-215.6C.
11

4. The annual administering and compliance fee shall be paid by the Permittee within 30 days
after being billed by the Division. Failure to pay the fee accordingly may cause the Division
to initiate action to revoke this permit, as specified by 15 NCAC 2H .0205 (c)(4).
5. The issuance of this permit does not preclude the Permittee from complying with any and all
statutes, rules, regulations, or ordinances that may be imposed by other government agencies
(i.e., local, state, and federal) which have jurisdiction, including, but not limited to, applicable
river buffer rules in 15A NCAC 2B .0200, soil erosion and sedimentation control requirements
in 15A NCAC Chapter 4 and under the Division's General Permit NCG0100000, and any
requirements pertaining to wetlands under 15A NCAC 2B .0200 and 15A NCAC .0500.
6, This permit may be modified, revoked, and/or reissued to incorporate any conditions,
limitations and monitoring requirements the Division deems necessary in order to protect the
environment and public health adequately.
7. The Permittee, at least six months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Division shall review the adequacy of the facilities
and residuals land application program described therein, and if warranted, shall extend the
permit for such period of time and under such conditions and limitations as it may deem
appropriate.
This permit shall not be automatically transferable. In the event that there is a desire for the
residuals land application program to change ownership or to change the name of the
Pern ittee, a formal permit request shall be submitted to the Division documentation from the
parties involved and other supporting materials as may be appropriate. The approval of this
request shall be considered on its merits and may or may not be approved.
Permit issued this the twenty-seventh day of September, 2002.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
for Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0012514
OCT - 7 200?
12

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Certification Date: September 27. 2002
Permit No. WQ0012514

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DATE: Feb'02
Town of Benson WTP
200? Town of Benson Site
Wastewater Treatment Plant Vicinity
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Certification Date: September 27. 2002
Permit No. WQ0012514

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SCALE: 11" = approx. mile:
CHECKED BY:
DRAWN BY: SDB
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Town of Benson
Jimmy Draughan Farm
Land Application Program
Site
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Town of Benson
Jimmy Draughan Farm
Land Application Program

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CHECKED BY:
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DATE: Feb'02
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Town of Benson .
Jimmy Draughan Farm
Land Application Program
If1A Mr r^_annn
Buffer
Map

Appendix 4.3 — Analysis of Residuals Land Application Permit vs. Lab Test Results
from Annual Monitoring Reports for 2002 and 2003

Town of Benson
Analysis of Residuals Land Application Permit vs. Lab Tests
From Lab Tests Included In 2002 Annual Report)
Constituent
Arsenic
Cadmium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Crop
Cotton
Alfalfa
Bermuda Grass
Blue Gress
Com (Grain)
Com (Silage)
Fescue
Forest (Hardwood
or Softwood)
Small Grain
Sorghum or
Sudex (Pasture)
Sorghum or
Sudex (Silage)
Soybeans
Timothy, Orchard,
or Rye Grasses
Permit Cellin
Concentrations 1 s. Lab Results
Constituent
Permit Calling
Concentration •
Dry Weight Basis
(mg/kg)
Constituent
Concentration
(Tested 4/24/01) •
Dry Weight Basis
(mg/kg)
Arsenic
75
10.13
Cadmium
85
16.48
Copper
4,300
778
Lead
840
64 81
Mercury
57
124
Molybdenum
75
83.16
Nickel
420
41.77
Selenium
100
6.33
Zinc
7,500
762.03
Note: All TCLP concenlralrons were Carnphanl
A Exceeded
Ceiling
Concentration
Cumulative Pollutant Loading Rates (CPLRU}
CPLR (Ibs/AC)
36
34
1.338
287
15
n/a
37.4
89
2,498
Permitted PAN
(Ibs/AC/year)
70
200
220
120
160
200
250
75
100
100
180
220
200
200
CPLR for 18.2 AC
(Ibs)
(CPLR•18.2)
655.2
818.8
24351.8
4859.4
273.0
n/e
6806.8
1619.8
45463.8
Constituent
Concentration
(Tested 4/24/01) -
Dry Weight Basis
(Ibs/ton)
(mg/k9•.002)
0.020
❑.033
1 556
0.170
0.002
0.166
0.084
0 013
1.524
Plant Available Nitrogen (PA14)
Permitted PAN
for 18.2 AC PAN
(Ibs/year) Concentration
(Permitted (Tested 4/24/01)
PAN•18.2) (Ibs/ton)
1,274 1 14.68
3,640 1 14.68
4.004 1 14 68
2, /84 14.68
2,912
3, 640
4,550
14.68
14.68
14.68
1,365 14.68
1.820 1 14.68
1.820 1 14.68
3.276 1 14.68
4,004 1 14.68
3.640 1 14.68
3,640 14.68
Dry Tons
Permitted on
18.2 AC site
(CPLR for
ta.2AC /
Constituent
Concentration)
32.340
18,797
15,650
28.649
110,081
n/a
61,480
127.948
29,831
Dry Tons Per
Year Potentially
Permitted on
18.2 AC site
(Permitted PAN
for 18.2ACIPAN
Concentration) •
87
248
273
149
198
248
310
93
724
124
223
273
246
No. of Years to
Meet CPLR
280 Dry Tons /
Year (Number le
for relative
Information only;
doss not account
for prior
applications)
129
75
33
115
440
n/a
328
512
119
Comment
A Crop Actually
Applied To
Other Potential
Crops
- Note. Actual permit' max+mum quanlrfy is 250 d tons 248
dry year. Quantity odes+duals azlual/y app/red+n 2002 was
25 14 dry tans.

Town of Benson
Analysis of Residuals Land Application Permit vs. Lab Tests
(From Lab Tests Included In 2003 Annual Report)
Constituent
Arsenic
Cadmium
Copper
Lead
Mercury
Permit Ceiiln(
Concentrations Vs. Lab Results
Constituent
Permit Ceiling
Concentration -
Dry Weight Basis
(mg/kg)
Constituent
Concentration
(Tested 2/18/03) •
Dry Weight Basis
(mg/kg)
Arsenic
75
9.18
Cadmium
85
1.91
Copper
4,300
366
Lead
840
37.3
Mercury
57
4.46
Molybdenum
75
11.4
Nickel
420
21.1
Selenium
100
9.18
Zinc
7,500
545
Note: All TCLP conceniralions were compliant.
Cumulative Pollutant Loading Rates fCPLRs)
CPLR (Ibs/AC)
35
CPLR for 18.2 AC
(Ibs)
(CPLR•18.2)
655.2
Constituent
Concentration
(Tested 2/18/03)-
Dry Weight Basis
(Ibs/ton)
{mg/kg•.002)
Molybdenum
Nickel
Selenium
Zinc
Crop
Soybeans
Alfalfa
Bermuda Grass
Blue Grass
Com (Gram)
Corn (Silage)
Conlon
Fescue
Forest (Hardwood
or Softwood)
Milo
Small Grain
Sorghum or
Sudex (Pasture)
Sorghum or
Sudex (Silage)
Timothy, Orchard,
or Rye Grasses
34
1,338
267
15
n/a
374
89
2,498
Permitted PAN
(IbsiAClyear)
200
200
220
120
160
200
70
250
75
100
100
180
220
200
618.8
24351.6
4859.4
273.0
n/a
6806.8
1619.8
45463.6
0.018
0.004
0.732
0.075
0.909
0.023
0.042
0 018
1.090
Dry Tons
Permitted on 18.2
ac site (CPLR for
18.2AC 1
Constituent
Concentration)
Plant Available Nitrogen (PAN)
Permitted PAN
for 18.2 AC
(lbslyear)
{Permitted
PAN•18.2)
3,640
3,640
4,004
2,184
2,912
3,640
1,274
4,550
1,365
1,820
1.820
3,276
4,004
3,640
PAN (Surface)
Concentration
(Tested 2/18/03)
(Ibs/ton)
7.37
7.37
7.37
7,37
7.37
7.37
7.37
7.37
7.37
7.37
7.37
7.37
7 37
7 37
35,686
No. of Years to
Meet CPLR
250 Dry Tons l
Year (Number Is
for relative
Information only;
doss not account
for prior
applications)
161.999
33,267
65,139
30,605
nla
161,299
88,224
41,710
143
648
133
261
122
n/a
645
353
167
Dry Tons Per
Year Potentially
Permitted on 18.2
AC site
{Permitted PAN
for 18.2 AC 1 PAN
(Suface)
Concentration)
494
494
543
296
39$
494
173
617
185
247
247
445
543
Comment
4 Crop Actually
Applied To
4 Other Potential
Crops
494
' - Note. Ac1ua1 permit maximum quantify is 250 dry tons / year. Quantity of res+duelsactualy applied in 2003 was
15.12 dry Ions.

Appendix 4.4 — Reclaimed Water Permit

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
RECLAIMED WATER GENERATION AND UTILIZATION PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Town of Benson
Johnston County
FOR THE
construction and operation of a 23,240 GPD reclaimed water generation and utilization facility with a
spray irrigation system consisting of a wet well with dual 180 GPM reuse water pumps, a flowmeter, an
on-line turbidity meter, approximately 7,750 linear feet of 6-inch and 1,400 ft of 4-inch reclaimed water
force main, a 6000-gallon pneumatic reuse tank, associated piping, and connection to the existing 7.1
acre spray irrigation field at the South Johnston High School to serve the Town of Benson, with no
discharge of wastes to the surface waters of the State, pursuant to the application received January 29,
2003, and subsequent additional information received by the Division, and in conformity with the
project plan, specifications, and other supporting data subsequently filed and approved by the
Department of Environment and Natural Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until June 9, 2009, and shall be subject to
the following specified conditions and limitations:
I. PERFORMANCE STANDARDS
1. Upon completion of construction and prior to operation of this permitted facility, a
certification must be received from a professional engineer certifying that the permitted
facility has been installed in accordance with this permit, the approved plans and
specifications, and other supporting materials. if this project is to be completed in phases
and partially certified, you shall retain the responsibility to track further construction
approved under the same permit, and shall provide a final certificate of completion once
the entire project has been completed. Mail the Certification to the Construction Grants
& Loans Section, Division of Water Quality, 1633 Mail Service Center, Raleigh, NC
27699-1633.

Town of Benson
Permit Number WQ0022501
June 10, 2004
Page 2
2. The Raleigh Regional Office, telephone number [phone], shall be notified at least
forty-eight (48) hours in advance of operation of the installed facilities so that an in -place
inspection can be made. Such notification to the regional supervisor shall be made
during the normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday,
excluding State Holidays.
3. The reclaimed water facilities shall be effectively maintained and operated at all times so
that there is no discharge to the surface waters, nor any contamination of ground waters
which will render them unsatisfactory for normal use. In the event that the facilities fail
to perform satisfactorily, including the creation of nuisance conditions or failure of the
irrigation area to adequately assimilate the wastewater, the Permittee shall take
immediate corrective actions including those actions that may be required by the Division
of Water Quality (Division), such as the construction of additional or replacement
wastewater treatment and disposal facilities.
4. The issuance of this permit shall not relieve the Permittee of the responsibility for
damages to surface or groundwaters resulting from the operation of this facility.
5. The residuals generated from these treatment facilities must be disposed in accordance
with General Statute 143-215.1 and in a manner approved by the Division.
6. Diversion or bypassing of the untreated wastewater from the treatment facilities is
prohibited.
7. The following buffers shall be maintained:
a. 100 feet between wetted areas and water supply wells,
b. 100 feet between wetted areas and waters classified as SA,
c. 25 feet between wetted areas and surface waters not classified as SA,
d. 100 feet between wastewater treatment units and wells,
e. 50 feet between reclaimed water storage/irrigation ponds and property lines, and
f. 50 feet between wastewater treatment units and property lines.
8. Public access to the irrigation sites shall be controlled during active site use. Such
controls may include the posting of signs showing the activities being conducted at each
site. A sign shall be posted in plain sight showing these activities.
9. All reclaimed water valves, storage facilities, outlets shall be tagged or labeled to warn
the public or employees that the water is not intended for drinking. Where appropriate,
such waming shall inform the public or employees to avoid contact with the water.
10. All reclaimed water piping, valves, outlets and other appurtenances shall be color -coded,
taped, or otherwise marked to identify the source of the water as being reclaimed water.
a. All reclaimed water piping and appurtenances shall be either colored purple (i.e.,
Pantone 522) and embossed or integrally stamped or marked "CAUTION:
RECLAIMED WATER DO NOT DRINK" or be installed with a purple (i.e.,

Town of Benson
Permit Number WQ0022501
June 10, 2004
Page 3
Pantone 522) identification tape or polyethylene vinyl wrap. The warning shall
be stamped on opposite sides of the pipe and repeated every three feet or less.
b. Identification tape shall be at least three inches wide and have white or black
lettering on purple (i.e., Pantone 522) field stating "CAUTION: RECLAIMED
WATER DO NOT DRINK." Identification tape shall be installed on top of
reclaimed water pipelines, fastened at least every 10 feet to each pipe length and
run continuously the entire length of the pipe.
c. Existing underground distribution systems retrofitted for the purpose of
distributing reclaimed water shall be taped or otherwise identified as in items a. or
b. above. This identification need not extend the entire length of the distribution
system but shall be incorporated within 10 feet of crossing any potable water
supply line or sanitary sewer line.
11. All reclaimed water valves and outlets shall be of a type, or secured in a manner, that
permits operation by authorized personnel only.
12. Above -ground hose bibs (i.e., spigots or other hand -operated connections) shall not be
present. Hose bibs shall be located in locked below -grade vaults that shall be clearly
labeled as being of non -potable quality. As an alternative to the use of locked
below -grade vaults with standard hose bibs services, hose bibs, which can only be
operated by a special tool may be placed in non -lockable underground services boxes
clearly labeled as non -potable water.
13. The Permittee shall maintain an active cross -connection control program that shall have
the following minimum requirements:
a. No direct cross -connections shall be allowed between the reclaimed water and
potable water systems.
b. A reduced pressure principle backflow preventer, an approved air gap separation,
or other device approved by the Division of Environmental Health shall be
installed at the potable water service connection to the use area where both
reclaimed water and potable water are supplied to a reclaimed water use area.
The installation of the reduced pressure principle backflow prevention device
shall allow proper testing.
c. An air gap separation, approved and regularly inspected by the potable water
supplier, shall be provided between the potable water and reclaimed water
systems where potable water is used to supplement a reclaimed water system.
II. OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities shall be properly maintained and operated at all times.

Town of Benson
Permit Number WQ0022501
June 10, 2004
Page 4
2.
Upon classification of the wastewater treatment and irrigation facilities by the Water
Pollution Control System Operators Certification Commission (WPCSOCC), the
Permittee shall designate and employ a certified operator to be in responsible charge
(ORC) and one or more certified operator(s) to be back-up ORC(s) of the facilities in
accordance with 15A NCAC 8G .0201. The ORC shall visit the facilities in accordance
with 15A NCAC 8G .0204 or as specified in this permit and shall comply with all other
conditions specified in these rules.
3. A suitable year round vegetative cover shall be maintained.
4. Irrigation at the South Johnson County High School shall not be performed during
inclement weather or when the ground is in a condition that will cause runoff.
Adequate measures shall be taken to prevent wastewater runoff from the irrigation fields.
6. The facilities shall be effectively maintained and operated as a non -discharge system to
prevent the discharge of any wastewater resulting from the operation of this facility,
unless authorized by an NPDES permit.
7. The annual spray irrigation application rate onto the four ball fields at the South Johnston
County High School (softball field, football field, baseball field, and soccer field) totaling
7.1 acres shall be according to the following table.
Minimum Cumulative
Loading over any 12
month period
(inches/year)
Maximum Cumulative
Loading over any 12
month period
(inches/year)
Maximum Instantaneous
Loading Rate
(inches/hour)
11.0 *
44.0
0.25
*The minimum annual cumulative loading rate of 11.0 inches/year is established to
assure a minimum level of irrigation onto the spray irrigation field. If the annual total
rainfall exceeds the 90`s percentile rainfall calculated for Smithfield in Johnston County
(57.3 inches/year), then this minimum annual cumulative loading rate requirement may
be adjusted by the Division.
No type of wastewater other than that from the Town of Benson shall be irrigated onto
the irrigation area.
1. No traffic or equipment shall be allowed on the disposal area except while installation
occurs or while normal maintenance is being performed.
10. All wastewater shall be discharged in strict accordance with the conditions of the
facility's existing NPDES permit should the limit for fecal coliform (daily maximum
concentration of 25 per 100 ml) or turbidity (instantaneous maximum of 10 NTU) be
exceeded, until such time that the levels have stabilized below these maximum levels.

Town of Benson
Permit Number WQ0022501
June 10, 2004
Page 5
III. MONITORING AND REPORTING REQUIREMENTS
1. Any monitoring (including groundwater, surface water, soil or plant tissue analyses)
deemed necessary by the Division to insure surface and ground water protection will be
established and an acceptable sampling reporting schedule shall be followed.
2. WWTP reuse effluent flow shall be continuously monitored and daily flow values
shall be reported on Form NDMR. Irrigation at the South Johnston County High
School shall be continuously monitored and daily flow values shall be reported on
Form NDAR.
The Permittee shall install all appropriate flow measurement devices consistent with
approved engineering and scientific practices to ensure accuracy and reliability of
influent flow measurement. Flow measurement devices selected shall be capable of
measuring flows with a maximum deviation of less than 10 percent from true flow,
accurately calibrated at a minimum of once per year, and maintained to ensure that the
accuracy of the measurement is consistent with the accepted capacity of that type of
device. Records of flow measurement device calibrations shall be kept on file by the
Permittee for a period of at least three years. At a minimum, data to be included in this
documentation shall be:
a.
b.
c.
Date of flow measurement device calibration
Name of person performing calibration
Percent from true flow
3. As an indicator of proper operation and maintenance, the facility shall produce an
effluent in compliance with the following limitations:
Parameter
BOD5 (5-day, 20°C)
NH3 as N
TSS
Fecal Coliform
Turbidity
Monthly Average a
10 mg/1
4 mg/1
5 mg/1
14 per 100 m1 b
10 NTU
Daily (Instantaneous) Maximum
15 mg/1
6 mg/1
10 mg/1
25 per 100 ml
a. Monthly averages for all but fecal coliform shall be the arithmetic mean of all
samples collected during the reporting period.
b. Monthly average for fecal coliform shall be the geometric mean of all samples
collected during the reporting period.
c. Daily maximum shall be the maximum value of all samples collected during the
reporting period.
The effluent from the subject facilities shall be monitored, by the Permittee, at the point
prior to discharge to the spray field for the following parameters (and reported on Form
NDMR-1):

Town of Benson
Permit Number WQ0022501
June 10, 2004
Page 6
Parameter
Flow
Turbidity
BOD5 (5-day, 20°C)
NH3 as N
TSS
Fecal Coliform
Settleable Matter
Residual Chlorine
NO3
TKN
TDS
TOC
Chloride
Sampling Point
Reuse Effluent
At WWTP Reuse
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Sampling Frequency
As Used
Meter
Continuous
*2/Month
*2/Month
*2/Month
* 2/Month
Daily
Daily
*2/Month
*2/Month
**Triannually
**Triannually
**Triannually
Type of Sample
Recording
Recording
Composite
Composite
Composite
Grab
Grab
Grab
Composite
Composite
Grab
Grab
Grab
The effluent pH shall not be less than 6.0 standard units nor greater than 9.0 standard
units.
* 2/Month sampling frequency only during the months of April through October.
During the remainder of the year, these parameters shall be monitored monthly.
Triannually sampling shall be conducted during March, July, and November.
**
If Groundwater sampling indicates or predicts problems with the compliance with
Groundwater Standards, this permit will be modified to include additional and/or more
restrictive limitations.
4. Adequate records shall be maintained by the Permittee tracking the amount of wastewater
disposed at the South Johnston County High School. These records shall include, but are
not necessarily limited to, the following information (and reported on Form NDAR-1):
a.
b.
c.
d.
e.
f.
g•
date of irrigation,
volume of wastewater irrigated,
field irrigated,
length of time field is irrigated,
continuous weekly, monthly, and year-to-date hydraulic (inches/acre) loadings for
each field,
weather conditions, and
maintenance of cover crops.
5. Three (3) copies of all monitoring data (as specified in condition III 3) on Form NDMR-1
and three (3) copies of all operation and disposal records (as specified in condition III 4)
on Form NDAR-1 shall be submitted monthly on or before the last day of the following
month. All information shall be submitted to the following address:

Town of Benson
Permit Number WQ0022501
June 10, 2004
Page 7
NC Division of Water Quality
Water Quality Section
Non -Discharge Compliance/Enforcement Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
6. A maintenance log shall be maintained at this facility including but not limited to the
following items:
a. Daily sampling results including residual chlorine, settleable matter, and
dissolved oxygen in the aeration basin and at the clarifier weir.
b. Visual obserr ations of the plant and plant site.
c. Visual observations of the spray irrigation site.
d. Record of preventative maintenance (changing of filters, adjusting belt tensions,
alarm testing, diffuser inspections and cleanings, irrigation pump maintenance,
changing sprinkler nozzles, etc.).
e. Date of calibration of flow measurement device.
f. Date and results of power interruption testing on alternate power supply.
7 Noncompliance Notification:
The Permittee shall report by telephone to the Raleigh Regional Office, telephone
number [phone], as soon as possible, but in no case more than 24 hours or on the
next working day following the occurrence or first knowledge of the occurrence of any of
the following:
a. Any occurrence at the wastewater treatment facility which results in the treatment
of significant amounts of wastes which are abnormal in quantity or characteristic,
such as the dumping of the contents of a sludge digester; the known passage of a
slug of hazardous substance through the facility; or any other unusual
circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the
facility incapable of adequate wastewater treatment such as mechanical or
electrical failures of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a
by-pass directly to receiving waters without treatment of all or any portion of the
influent to such station or facility.
d. Any time that self -monitoring information indicates that the facility has gone out
of compliance with its permit limitations.
Occurrences outside normal business hours may also be reported to the Division's
Emergency Response personnel at telephone number [phone], [phone], or
[phone]. Persons reporting such occurrences by telephone shall also file a written
report in letter form within five (5) days following first knowledge of the occurrence.
This report must outline the actions taken or proposed to be taken to ensure that the
problem does not recur.

Town of Benson
Permit Number WQ0022501
June 10, 2004
Page 8
IV. GROUNDWATER REQUIREMENTS
1. Waste application activities shall not occur when the vertical separation between depth of
application and the water table is at less than one (1) foot. Verification of the water table
elevation can be confirmed by water level readings obtained from the monitor well(s)
near the site or auger boring(s), which must be done within 24 hours, prior to application
of wastewater. Any open borings must be properly filled with native soil, prior to
application to decrease the chance of any waste contaminating the groundwater.
The compliance boundary and review boundary for wastewater disposal systems are
specified by 15A NCAC 2L. For systems utilizing reclaimed water, 15A NCAC 2H
.0219(k) specifies that both the compliance boundary and review boundary shall be
established at the property line. An exceedance of groundwater quality standards at or
beyond the compliance boundary is subject to immediate remediation action in addition
to the penalty provisions under North Carolina General Statute 143-215.6A(a)(1).
3. Any groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
V. INSPECTIONS
1. Adequate inspection, maintenance, and cleaning shall be provided by the Permittee to
insure proper operation of the subject facilities.
2. The Permittee or his designee shall inspect the wastewater treatment and disposal
facilities to prevent malfunctions and deterioration, operator errors and discharges which
may cause or lead to the release of wastes to the environment, a threat to human health,
or a nuisance. The Permittee shall keep an inspection log or summary including at least
the date and time of inspection, observations made, and any maintenance, repairs, or
corrective actions taken by the Permittee. This log of inspections shall be maintained by
the Permittee for a period of three years from the date of the inspection and shall be made
available upon request to the Division or other permitting authority.
3. Any duly authorized officer, employee, or representative of the Division may, upon
presentation of credentials, enter and inspect any property, premises or place on or related
to the disposal site or facility at any reasonable time for the purpose of determining
compliance with this permit; may inspect or copy any records that must be maintained
under the terms and conditions of this permit, and may obtain samples of groundwater,
surface water, or leachate.
VI. GENERAL CONDITIONS
This permit shall become voidable unless the facilities are constructed in accordance with
the conditions of this permit, the approved plans and specifications, and other supporting
data.

Town of Benson
Permit Number WQ0022501
June 10, 2004
Page 9
2.
This permit is effective only with respect to the nature and volume of wastes described in
the application and other supporting data.
This permit is not transferable. In the event there is a desire for the facilities to change
ownership, or there is a name change of the Permittee, a formal permit request must be
submitted to the Division accompanied by an application fee, documentation from the
parties involved, and other supporting materials as may be appropriate. The approval of
this request will be considered on its merits and may or may not be approved.
4. This permit is issued pursuant to T15A:2H.0219(p) for the construction and operation of
a reclaimed water utilization facility without flow equalization. In the event that
non-compliance with any permit limitation results from the absence of flow equalization,
this permit may be administratively reopened, and a requirement for the construction of a
flow equalization basin may be incorporated into the permit.
5. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division in accordance with North Carolina
General Statute 143-215.6A to 143-215.6C.
6. The issuance of this permit does not exempt the Permittee from complying with any and
all statutes, rules, regulations, or ordinances which may be imposed by other government
agencies (local, state, and federal) which have jurisdiction, including but not limited to
applicable river buffer rules in 15A NCAC 2B .0200, erosion and sedimentation control
requirements in 15A NCAC Chapter 4 and under the Division's General Permit
NCG010000, and any requirements pertaining to wetlands under 15A NCAC 2B .0200
and 2H .0500.
7. The Permittee, within 90 days following issuance of this permit, shall request
modification of NPDES Permit No. NC0020389 issued to the Town of Benson
wastewater treatment facility. The modification shall amend the existing NPDES permit
to allow the conjunctive use of reclaimed water as provided for in this permit.
8. A set of approved plans and specifications for the subject project must be retained by the
Permittee for the life of the project.
9. The annual administering and compliance fee must be paid by the Permittee within thirty
(30) days after being billed by the Division. Failure to pay the fee accordingly may cause
the Division to initiate action to revoke this permit as specified by 15A NCAC 2H .0205
(c)(4).
10. The Permittee, at least six (6) months prior to the expiration of this permit, shall request
its extension. Upon receipt of the request, the Commission will review the adequacy of
the facilities described therein, and if warranted, will extend the permit for such period of
time and under such conditions and limitations as it may deem appropriate.

Town of Benson
Permit Number WQ0022501
June 10, 2004
Page 10
11. This permit in no way negates, precludes, or invalidates the most recent reissuance of
NPDES Permit No. NC0020389, and the Permittee shall continue to comply with all
conditions provided for therein.
Permit issued this the loth day of June, 2004.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Alan W. Klime ..E., Director
Division of W r Quality
By Authority .fthe Environmental Management Commission
Permit Number WQ0022501

Appendix 4.5 — 2004 — 2006 Operating Data

Daily BOD5 (mg/L)
Avg. %
Removal
97.1%
95.3%
96.6%
97.8%
98.5%
99.0%
98.0%
99.9%
99.8%
95.5%
93.6%
97.8%
Effluent
Average 'Minimum Maximum
4.6 2.1 7
3.4 0 5.8
2.5 <2 6.3
1.8 <2 13
1.2 <2 3.9
1 <2 3.5
1.8 <2 24
0.1 <2 2.1
0.1 <2 2.4
3.3 <2 7.3
4.9 <2 19
1.7 <2 606
..�
q
61
rz
Average Minimum Maximum
161 72 420
73 <40 110
73 30 170
81 0 140
79 33 173
101 0 400
1 90 46 130
79.8 29 190
56 26 170
74 43 180
77 0 160
77 44 102
1
Daily Temp. (°C)
Effluent
Average Minimum Maximum
13.5 10.8 18.2
13.4 11.2 15.8
15.6 13.2 17.2
17.8 14.1 20.3
21.9 17.2 25.2
24.3 21.2 25.8
26.3 24.2 28.1
24.2 22.1 25.7
24 22.3 26.5
21.6 19.2 24.9
20.6 19.1 24.4
16 10.1 19.7
Daily Flow (mgd)
Average Minimum Maximum
0.883 0.584 1.233
1.269 0.725 1.917
1.137 0.505 1.717
0.846 0.533 1.265
1.071 0.681 1.807
1.214 0.674 1.824
1.085 0.617 1.917
1.433 0.694 2.848
1.688 1.012 2.504
0.965 0.684 1.279
1.001 0.673 1.49
1.031 0.699 1.418
v
0 0 0 0 0
�. - + �; +
g bo
,zrel
00
00
00
L
cu
0
v')
00
N Q
z
67.
00
Cr)
cn
N
a
a)
ul
00
v1
z °
00
0
0
U
vl
O
N
0
0
-0

Nitrates/Nitrites
Effluent
(Average IMinimumIMaximum
N [� 00 •-1 .--i en•--• C1 vn tin 10
N M •--, ‘..0 t� �f N 00 .� 10 l-- N
00 M V'1 N M N N 4 N 4
N01OCV
VD i\0 O 0) O. S.-.-, O .-, -O O — -, .-N O •-00
N.
O 0000 N O� t -' M O N 0 VD
4 Ni Ni vi N r-+ N �j —, r.j •'" N
Daily NH3 as N (mg/L)
Effluent
�Averagei Minimum Maximum
l� 1D C1 •-, 1D ct 01 [� N M v1 sst
vD M O1 00 M O. �t M C1 N l� ct
O O O 0 0. O O O O N O
d
O O V O N O V
0 0 0 V 0
M N N M N M •--, N M •--i O M
O O O O O O O O O •--+ •, O
Daily Total Suspended Solids (mg/L)
Avg. %
Removal
000000000000
cr .--• 00 I� M •� [� I� C1 N •-1 O
[-: N M •--: M V'1 4 V1 4 N N V1
01 C1 C1 C1 C1 C1 C1 C1 C1 01 C1 C1
Effluent
Average Minimuruii Maximum
00 Ul N V) M •--! M 00 00 00 M
M M N C1 vi •-, •--, C Q\ 4 4 (Ni
N M 1D ,--i v) [� M N VD r
00 00 00 01 Cr1 C1 C\ .--+ M .--4
N Vl 10 N • N O C1 en • 4
00 01 N N 00 N vi 10 (:, C 10
N
I.0
..0
Average Minimum Maximum
O C1 l� M V1 VD N 00 l - 10 N 00
O O N M O 01 O C1 v) vi \D
,M_, N N N N -+ N •-- -- --.
71-
CT 0000 0000 CD0000 N C1 0 CT OD C1
M N N N M N •--, N N
01
.--- .--,
O O O O O i O O O O O O
i 1
(Fd^ y cd G cC 0 0 U O U
''w Q �`-'dVIOZCa
N
00
V)
N
01
10
00
C-
N
O
z
N
z
VD
•71-
O
vl
Data does not meet permit limits

Daily Dissolved Oxygen
(mglL)
Effluent
Average Minimum1Maximum
VD M 00 VD N N N vl
.Cl\ O Oa1 00 ' 00 00 00 O' a1 D;
Is VD V1 l� M M •-.. M [s M
00 00 00 l- l— I— [- [- t- VC 00
00 01 01 00 00 00 C- 00 00 00
Total Phosphorus (mg/L)
Effluent
Average Minimum'Maximum
ON v'i vl M N •"' d- M N V'1
DO le:l O O O O •� 0 0 0 0 •-'.
00 00 N VD v) t` Cl 0\ 00 00 00 0\
M 00 [s 00 [s Vs 00 v1
C O C O O O 6 O C O C O
M CN 0\ 01 M VD \D VD VD 01 d- N
V1 O 00 0\ 01 00 00 0\ 0\ 0\ 00
6 r-' 0 0 0 0 0 0 0 0 0 0
Monthly
Total
Nitrogen
0
i.
10 VD v7 VD N •--' d' `0 M r• .--i
O is O M d O M 00 r N N
M O N N 00 O N •--, M N
Total Nitrogen (mg/L)
Effluent
Average IMinimum1Maximum
00 vl is VD kn 00 O -. N v1 O
v i VD N •-. vi oo O Oh M 00 l-
01 -4 0\ I-: M 4 4 M l-: 00 lC
M M .-. \D VD •-, Vs 00 O 00 M
VD O O d O Vs •-, [s O N
N N N M N N N N N M M M
•-. •— O 00 O 1` Vs M •--' CN is 00
Vs v1 •� N v") [- v1 M 00 N v1
v'i M 4 �C 4 N M M N vi vi 4
E
Effluent
[Average [ Minimum] Maximum]
-. 1 ON is
kr) VD •. vN ,� 00 d- ON •--+ is VD . 7t
N •--•1 ~ ~ N VO N
cq
-. M onkq ON O V- ct N
r vl [- „O N r- vn \D is is ON
4:)N 11•N a O vl 00
O O O O O O O O O O O O
cC CL c4 O i 0 8 O1 01 N
'—'w Q ti Q(1)OZQ
00
•
O
1111.
rl
00
•
CT
er
Ire
r1
(Quarterly Avg.)
N
Permit Limits
O
VD
(Quarterly Avg.)
O
N
(NC0020389)
Data does not meet permit limits

Total Nickel (ug/L)
Effluent
Average Minimum Maximum
O O O O O O O O O O O M
V V V V V V V V V V V '~
O O O O O O O O O O O O
V V V V V V V V V V V V
0 0 0 0 0 0 0 0 0 0 0
V V V V V V V V V V V
Total Mercury (ng/L)
Effluent
Average Minimum Maximum
en
ell ,--4N en N M-+ vG V6 �O Oi
.--. Vl M N M .O O, QN N
M v l� 0 Cl* v 0 ,--,. O •---1 Lien
,--i '-- M ^. M VO VO 01
V1 N M V1 00 M ,--I N V1 00 M
[-- 00 t� N N V) r-+ N 00 as N,
N -4 ,--1 N 4 4 M 4 00 00
Daily Total Residual Chlorine
(mg/L)a
Effluent
(Average IMinimumIMaximum
--, QA vO l� N On N N M M M
V1 M d• M V1 M d: V1 \O
O O O O O O O O O O O O
—i 00 00 00 00 N vD 00 N 00 00 00
N N .--, N N N ,--, N N N N N
0 0 O O O 0 0 0 O O O O
V1 M V1 V1 .-r 00 N M N VD S
V) en M N M M N M M M M M
C O O O O 0 O O O O 0 0
Daily Fecal Coliform
(# / 100)
Effluent
Average Minimum Maximum
M O O N 00 [-- GN 00 N •71-
M N V1 Oh N M NNNNN
VNVV V V V V V V V
I� M M 00 V1 M M N M N M
d-
O O O O O O O O O O O O
cd ti V
''w d `' dcA0Zrzi
161
V
01
00
M
L
0
N
00
00
N
00
00
N
N
a The WWTP was not dechlorinating, the facility was being repaired
71.
.et
Water Permit
Data does not meet permit limits

Total Chromium
(ug/L)
Effluent
a)
v v v v v v v v v v v v
Daily pH
Effluent
MinimumjMaximum
NN N N NO N N N ,-1
,--i d kr) 01 [� 00 VD N O\ 00 N
[� V1 kr) .77 \O 00 l� VD V1 I�
VD vD uD v6 qD vD v6 D vD
Total Zinc (ug/L)
O
a>
O
Irg
14
Average Minimum Maximum
l� 00 l� v.M \O O\ M 00 00 U1
N l� VD .--, 00 N h l-- N O l� 00
M '-+ r 00 N N kr) en M .-r )!1
kr) V1 )n M v1 00 O O \D .-i
d' N �o O if;3 N t�
en M ""' cc)N q)
Total Copper (ug/L)
Effluent
Average Minimum Maximum
O O O N O N 00
V V V V
O O O O O O O O O
V V V V V V V V '—' V
0 C. O o
Conductivity
Effluent
Average MinimumlMaximum
1/4,0 4D M . N 1- 1- 00 00 \O .1- O
N N t� N 1- M Vl 10 0 V1 00 D
M M M M N M M M men M M
M N VD N --, N N O\ 1- VD N -1-
kr) kr) lP) \D 0 --4 M 0 VD
N N N N M N N N N N M N
,--i O O kr) r , vD —+ M l� O Cr, Q\
00 00 [� l� 00 l� ,--, N M O —
N N N N N N M M N M K1 K1
O O O O O O O O O O O O
I �+ 1
"w d '' v) O o a�i
� ¢ zA
N
u
ti
M
I
fel
00
Cr)
00
O
1/40
Uzi
Water Permit
Data does not meet permit limits

Daily BOD5 (mgfL)
Avg. %
Removal
0 0 0
0 00 0 00 0 0 0 0 0 0
D I� v' 01 I� ,-, N [� 00
•--, •--,1 M ON ^-kr) M l-: k!i V1 l� l-: l� vO
0\ 01 01 01 0\ 01 01 01 01 01 01 01
0:
z
Average IMinimum1Maximum
0 0 0 0 ,_, D1 ,__, O ,_,., M
4 ' c`ivD o0 00 N c-i 4 c-i
O O •--- O • O• O kr, - 0 0
O 4 N V V N V N N N N O
vo 01 M 01 01 O Cl U1 00
N N 4 M 4 M M 4 vi M N N
Influent
Average (Minimum Maximum
O O O O co co O O © O O co
O O O O_ O O cr; O 0 0 0
- N -- N 00 -- n N N
O O O O O O O O O O O O
C 4 N 4 O o0 10 O 1G N M 4
vo v1 d- d- 10 d- d- 01 10
00 0 00 0 0 0 0 0 0
kr; N 01 O O 0 M 0
00 01 00 l - 00 ^"_, O O1 ,~_, - 00
Daily Temp. (C)
Effluent
Average Minimum Maximum
00 I� 00 01 •-, \O l� •--, 01 00 M N
0\ 00 •--, cri ri 01 O 01 00 •-, 00
. . . N N N N r1 N N N-
V'1 M O N •--, -, M M kr) d- d-
01 O -- 000 N N N N- k •---
01 VD O 00 d O 01 01 M 10 O t�
M M \O 00 . N 4 M 01 M
. . . N N N N N N •--4
Daily Flow (mgd)
Average 'Minimum 'Maximum
O� N N VD 000 ,..0 00 O 0000 kr)O a vo
V'1 M l� N O 00 •--: M 00 111
— •--- N •--. — — M N I ,-i ,--i N
O N 00 vl •--( 10 M 'IT 0\ 01
01 N M ,--, O O O O, -+ kr,
O O O O O O O O O O O O
M —, 10 (-14 01 01 M O oo M 0
[— —, kr) N O d' 00 .� h
O O .--,. •--,. 00 l-- 01 01 00 0o oo cc.)--, —,—,-, o 0 0 0 0 0 0 •--,
cn cn v.) cn cn kr) kr) v-, kr) kr) kr) v)
O O O O o O O O o 0 o O
'mow ¢ `0""dcnOZ°0
A
ti
01
01
M
N
N
01
0
00
O
00
M
N
U
0
00
11
(NC0020389)
O
N
N
c)
U

Nitrates/Nitrites
Effluent
•
Average Minimum Maximum
t� O t� ul O\ o O M ,--i
00 00 t� t� N O 00 •--i N
4 vi \O 4 in M N N M
t-- N O t` O\ N M O O\
M vl N O ©. d OI t� f
M --. -, -� O •— vow
V1 N t- M o0 O ,--, 00 .--, •--•
O\ O\ 00 \O M ND ,--i 00 M O\
N M d' N N N N.
O\ 0 1
O K1
rl vO
�t
u1 NNN
•-
01
M v1
N ri
Daily NH3 as N (mg/L)
Effluent
Average Minimurr!Maximum
00 M N \O o0 .-. N N M v1 N ct
\O Ln O\ N \O O o0 .--, M
O --4 O O .--i O N 0 0 0
co O co co O
ino—o „ o—o N , N O— •--� .-+ .� .--,
C O V O O V C C 1 V V V
V'1 co ,--, O co O O\ "t 00 .--• .-.
M \O V'1 Vl M M M t� N N N
O O O O O O O O C O O O
Daily Total Suspended Solids (mg/L)
Avg. %
Removal
0 0 0•0 0 o o o 0
\ \ \ \ \ \ \ 0 \ \
\O O\ O\ 00 \O O\ 00 --. 00 M
M N 4 4 4 N 4 \o .--i \O
O\ O\ O\ O1 O\ O\ O\ O\ O\ O\
0 0
\ \
,--, \O
t` .G
O\ O\
C
0
t-
14
Average !Minimum' Maximum
0 0 0 0 0 0 CO 0 0
.1' M "" O N .-. 00 00 00 O\
l� DD l� . \O \O \p ~
o co co co O O O co co co O O
co M N or,O '� 0 0 vn
vi vi 4 4 4 C C 4 .--- .—,
NC) Q1 O en en N v1 O\ t� In V1
O V1 00 in O 00 a1 O\ O t�
00 00 \O vl \O vl t-4 4 o 4 v) 4
Influent
Average Minimum Maximum
00 M V M M M eh V'1 t— .—,
\O M V1 M d' Vl V1 V \O ,--,
N
~- CO 00 a -A tom~- N N \O
\O ON 00 .� ~ 00
.M-i .--i .N—i .--i N .M-+ - - an.rn M--
.-1
\O vO
V'1 \O
N N
M N
ON
an
- —I,--.
V) c l V1 V"l kr) VI VI Vl V'1 V1 v1 In
O O o O O O O O O O O O
ccdd N cd O. cd O O Ga) U O> 0
'mow d ti'�d' OZA
er
a\
00
VD
O
N
0
00
O
M
�z p
00
00
N
U
\O
Data does not meet permit limits

Daily Dissolved Oxygen
(mWL)
v
=
E
W
Average MinimumlMaximum]
'..0
01
vO
r
kr)
00
01
01
V1
06
M
ers
01 — t� ,--. 01 .D V1 V1 01
00 O 00 00 00 t� t� 00 0ri
00 00 v:) N . O 00
r r r t` r r r vc r
M tt ,--i 00 N M M \O VD
00 00 00 t- t-: t� t� r 00
N
o0
VD
01
Total Phosphorus (mg/L)
Effluent
Average Minimum'Maximum
,--, M 00 t- t- t-- \O vD ,--, 00 00 kr)
O oO D\ 0`O t" ,--'. v1 N O
00 00 O N __ ONO ONO a 0r0 VD VN'r
O O ,--, ,--, C C '—' O O O p
kr, —, N 00 VD N kr)01 kr) 00 4. ? N kP) 01 ,--,. 01 00
Monthly
Total
Nitrogen
0
E
ai
M
MN
M V1 \D -,
00 \D t-
vl O., © 00
t�
N
t—
M
O
kr)
1O
O
00 .--i 01
. N
N r- s
.1-
O
VD
Total Nitrogen (mg/L)
Effluent
Average Minimum Maximum
O 01 r-, 0\ O 01 N \O O N
M V'1 V1 r--VD VD r-, N O �O
r 0C kr); o; v6 01 kr; 00 4 r
,--, M 01 4 V1 M VI t� N VD t-
N 0\ N 00 t-- VD vD t- r1 vO N
N 4 4 N N N M N M N N M
4- V1 4- M 01 00 N 01 --, 01 M .
00 4 t` O M ,--, O Cl VD
VS VD M 4 4 v1 4 \D M M 4
Effluent
•
Average 'Minimum Maximum
M
N
Cl
.-,
01
00
.-:
01
t—
M
00
,-,
M
V'1
N
N t— .-+ 01
O M 01 N
("Ni .--, ,--, N
C2`r!M
p .--1 ,-1
t� .-. N 00
t� .-+ t� t�
r: ,-: ,-: .--
VI ---- 10 V1 V1
,--, 10 N
01 ent� .-: ,- ,
in'--' � N 01
ri r-i N r.I O
Cl ,--, O t- 01
vD M n M O
M N 4 ,-: ,—,
M
Cl
.�
10
O
N
O
.
kr) V1
IIIIO O
tiw
kr) kr)
O O O
d
N kr) V1 U1 V"1 V1 V'1
O O O O O O
ti'�Qti�CZCa
(Quarterly Avg.)
O
N
O
01
M jm
M
'd
.
os
04
Water Permit
Data does not meet permit limits
u)
0
M
a)
0)
0

Total Nickel (ug/L)
A
=
Ei
41
Average Minimum Maximum I
0 0 0 „� O O O O N O O N
'" V V V V V V V '-' V V .-
O O O O O O O O O O O O
V V V V V V V V V V V V
0 0 0 r 0 0 0 0 0 0
CI)V V V V V V V N V V N
Total Mercury (ngfL)
Effluent
Average Minimum Maximum
N 0 0 0 0 0 0 0 0 0
00 N [� • D\ N mf N•
N N d- mt •vi \O • t-- M • N ".
ON O O O O O O O O O O O
vi 4 -. -. ^. N N .. V -.
cc N O M O 00 O 00 00 [�
a1 r N M O M O N
O N O N N M 4 M 4 N ".
Daily Total Residual Chlorine
(fig-)3
Effluent
Average Minimum Maximum
O O O O CD CD CD CD CD CD CDO O O O O O O O O O O O
0 0 0 0 N 4 M (Ni N N v'i (Ni
N M N M
O O O
O O O O O O O O O O O O
O C O O O O O O O O O O
N N O O O O O C O O C
O O O O
0 0 0 0 0 0 0". vl `O O
C 0 0 0 0 l� M o0 ^' N`
O .r --- \O v) 4 vl M M v1 4 M
M d- M M
Daily Fecal Coliform
(# / 100)
a)
Average Minimum Maximum
0 0 0 0 0 CD 0 0 0 0 0 0
N \O M M 71:4 M M o0 M 00
M N —, M o0 " \p \p \O \O \O v-)
_ VV V V V V V V V V V
,_, 01 d. M O1 O d' O M r
N N '-+ N M O1 00 '-' N M P. ClM vl .-'
M N �--+
v1 vl v1 vl vl v1 vl II un vl vl v'i
O O O O O O O O O O O
w d a""tiQv)OzC
V
er
N
rl
V
00
V2
ir
0
N
00
00
N
\O
N
00
00
N
N
zICI
13.
•
00
00
N
U
vl
N
Data does not meet permit limits
1.0
O
O
N

Total Chromium
(ug/L)
Effluent
G)
V V V V V V V V V V V V
Daily pH
0
O
E
MinimumfMaximum
M ,--, N N N N N N N N N N
O ,--, N --, .--. N N N N
V1 . `O v'1 ,O vl 00 \O m
Total Zinc (ug(L}
Effluent
Average (Minimum Maximum
O 00 N O tr
QN CI �D M M v1 OO M \D lO
M ON N M M N OO N N [� O
[- v1 M to -- M M
Total Copper (ug/L)
=
wV
[Average jMinimumLMaximum
Ncn t- O O O O r 00
'_' - - - - V - V '" V V
O_ , O_ O_ O O O_ O _O O O O_
'"" V V '-' _ V_ V V V V
VD
VD N v'l v? M O O_ N O v1 O_ O
i -
roo vi '-' ,-. V ' v oo V V
Conductivity
N
+-
Average _IMinimumIMaximum
N VO M N N
d-O N t- 00 N 00 00 00 M C
MMMMMMMMMMMM
M-N N WO N M M N N N 'ct \O
VO N O N O ,.O N N N v1 N
N N N N M N N M m M N m
M-N N 1n 00 \O N M M r vl
CT 00 ['- ‘.O M In M N v1 [�
N N N N m m m M c"'1 m M M
Ln kn m u1 v� u1 ul m v1
O O O O O O O O O O O O
ccd N C]. usO O O a) U 00 N
ti w d on' d O Z
I
ti
M
VO
M
ue.
0
VG
00
00
N
U
g4
Water Permit
Data does not meet permit limits

Daily BOD5 (mgfL) ,
Avg. %
Removal
0
enO
[:
01
0 0 0 0 0 0 0" 0' 0" 0
C I— V1 v1 ul .,--i V1 00 00
[� [� S O\ O\ O l� 00 00 S S
01 01 01 01 01 01 01 01 O\ 01 01
W
Average Minimum Maximum
01
M
O
N
I--
N
V1 Vl 10 V1 O 10 01 10 I— 00
10 l-: kei M M N M 4 N 4 M
0 0 0 0 0 0 0 0 0 0
N V V V V V V N V N N
[— V1 l— M V1 M M ,--4 V1 el-
M 4 N O O O N N N N N
a)
=
O
Average MinimumjMaximum
O
v1
N
01
N
V
O
�--4
O O O O O O O O O O O
0 V1 O O C 0 0 0 V1 O
A N N -4N N N ON
O O O O O O O O O O O
c-V en
rn 011 1o �V dr r- VD VD
O O O O O O —4 O O O O
O 01 v, 4 Ki ,•i v'i -4 O 4 01
- - - 01 01 10 0, ,- - -
Daily Temp. (°C)
=
LTA
Average 1Minimum Maximum
N.
10
.--4
00
N
N
4
--4
M 1D "I M O1 N 10 1D en en
kr> O N V1 I- -4-4 O1 4 4 4
^-4 N N N N M M N N N ,--,
00 O O\ [� 00 V1 ul N N \O 10
O M M V1 [� 01 10 M
N N N—, .-� —400
00 M V1 M N l— [-- 1D N ^-4 01
N v1 01 . 10 00 O; N C o0 N
-4 -4 -4 N N N N N N r-+ ^4
Daily Flow (mgd)
Average Minimum Maximum
—4
N
N
—4
10
00
O
01
'' '
N
10 V1 co M O O1 10 v1 10 0000
--4 00 l- d' O O 10 ul O1 N
N —4 .--4 N N N —4 —4 —4 N N
O v1 O N V1 M O1 l ---4 V1
l— O1 O 01 V1 V1 —i 00 s
10 V7 r- 00 I— 00 O\ 00 10 v1 O1
O O O O O O O O C O C
00 10 in M [— 00 N M 00
10 M 01 V1 01 ,--i —4 .-4 01 •71-
O —, 01 O N N-- ---: O v1
O
1D
O
ad
10 10 10 10 1D 10 10 10 10 10 10
o 0 0 0 0 0 0 0 0
1 1. >, - 80 a 1 0
w Q Q O Z Q
V
01
V
0
0
00
V1
O
00
N
O
U
cu
w
gC
Z
a)
a
v1
44
z
A-1
•
00
00
0
O
U
V1
O
N
M
N
O
v
a)
O
N
N
O
O
•
a
i

Nitrates/Nitrites
Effluent
Average Minimum Maximum
•--• N O M ir) in o0 \O •--.
V1 M C� V1 C� O\ M N 0o V1 V1
4 (Ni oC •--; M C •, 4 M
--, 00 O N VD •� kn 0o t-- ON N
NO N N NO ON O in l� vO \G 1O •:
•, N ,--, ,--, O -� 0 0 0 •--, O
\O O, (` •--, O . oo O\ O'N O
OT M kr) N N O oo O. d- kr) o
N N 4 �O •, N O •--, N M N •--.
Daily NH3 as N (mg/L)
Effluent
Average MinimuniMaximum
00 O, N N N •-4 NO N O M o 0
N V1 d• 00 NO M M d• 00
O O O O C O O O O O O O
O O v 0v O v v v O O O V
00 .O VD M •--t O N •--,
—, N N N N •--, N N N M N N
C C O O O C C C O O O O
Daily Total Suspended Solids (mg/L)
Avg. %
Removal
sg 000000000000
v1 [� O Oi O M ci N
vO vO 4 16 \O in vi \O 16 11:3
ON ON ON ON ON ON O1 ON a1 ON ON ON
Effluent
Average Minimum' Maximum
0 0 0 0 0 0 0 0 0 00
•-. N N
00 \O 00 00 O 00 \O O\ 00 [-:
O O O O 0 O O O O O O O
t� O [� 4. N 4. •--, M O o0 O O
,O 01 kr, .� kr, l� o vO •, ON N VD
•-4 N O M N l� VD O •--, M M
V1 til 00 4 4 V1 V1 kr; V1 Vl kr; kr;
Influent
(Average IMinimumiMaximum
O O O O O o O O O co O O
O 0 1O N 1O 4 N O enN •--, 00 00 l� 111 a1 In vO cr, NO
N M
O O O O O O O O O O O O
O. O l-: •--, •--, O kO 4 O N
•--, N N M M N •--, N N N •--- N
O ON O o 0 0 0 0 00 co. O O
1O o0 N M N 4 4 N l- •--, N •,
ql-NO
NO NO NO NO NO NO NO VD \O VD VD
O O O O O O O O O O O
s O '¢ A C O. t > U
`'w '- QvOZL
Ir
6
N �
0
00
O
N
zQ
•
00
oo
M
O
N
O
O
u
NO
0
Water Permit
Data does not meet permit limits

Daily Dissolved Oxygen
(mom)
Effluent
Average I MinimumIMaximum
N N 0 0 O O O O OCT O N
' ' ' O 0\ O� 00 00 00 © ©
O O O O O co co O O O O O
t- 00 N M co .--, M l� N 01
t� O00 00 N \O \O \O t� 00 00 00
? On O OOi O N N 000 N o00
01 6 6 Q1 t. t-: t- 00 00 O O�
Total Phosphorus (mg/L)
Effluent
Average IMinimun1Maximum
. oo O O N v1 cr 00 O oo 00 \O
O. t� 0\ 0\ 00 0\ 00 00 00 00 0\ 00
-, O O O
. v1 V1 00 O 0\ N 0\ N O M U1
00 \O \O 10 [� M t� Lot:). v1
O O © © .- - .-r © .- -, .--i .--i
O O t- . t- V1 t- •-• --, O
0\ t- 00 t- v1 t. t" ul S. 00 00 t-
O O O O
Monthly
Total
Nitrogen
(lb/mo)
10 ,O •-. v1 N O v1 t� M N •'-1
t- ‘.D r •--• VD M O N •--1 M \O V1
N 00 in, O 10 N. in\p O N. N. 01
.--i .--- N .--1 ,-1'.—i .--I
Total Nitrogen (mg/L)
Effluent
Average IMinimum Maximum
VD VD N r+ t� O1 00 O v1 .--, N
kin 00 00 C. 00 01 t- O O
V1 M 01 6 N 00 --, N v1 t- vl M
.4 s.O N . v1 01 t� N
1,1 t• M v1 ., d' t� if:). O\ V1 1
N N N M •-, N •--o • -, N •-, N
V'1 01 00 00 .--, en 00 N O t—
O N t- 01 01 10•- v1 t-- •--, v1
4 M 10 t� .--. M •--, N M 4 M N
t
E
Effluent
Average IMinimumIMaximum
M qO O O M 4 M 00 10 O
111 v1 t� N 0. M `11
01 M 'Cr N M 0000 VD N N 00
O C. •--, O O O O O O O O
'--. O O •� O .1t t� N 00
•—. Cl t'v1 O 00 .. O " O ".
-- .-� .-r ... 0 — 0
VD \O \O 10 VD 10 10 VD VD vD VD 10
O O O O O O O O O O O O
cd i i i i —:. 1 i i 3
tip, Q `�-"<cipOZQ
0\
00
00
1-4
M
t`
0
O
VD
(Quarterly Avg.)
O
VD
(Quarterly Avg.)
VI
•
0\
00
M
0
O
O
U
.es
Water Permit
Data does not meet permit limits

Total Nickel (ug/L)
Effluent
Average IMinimumIMaximum
CD
V
O
V
O
V
N .--4
O O
V V
N
1/1
_,OOOOOOOO
.--4 V V V V V V V V
O O O O O O O O O
V V V V V V V V V
r CD CD CD CD CD CD CD CD
(Ni V V V V V V V V
Total Mercury (ng/L)
Effluent
Average Minimum Maximum
CD CD Ocq D CD
— N N N
0 0 0
v .1 -.-.
O M 00 O
-, 01 Cr)
•, -.-. -.
CDN
00 00
0 0
o-.
M O
v1 N
M vD
CD ri C 77 CD 0 0
'--, ,t V .. -. V
0 O O O
v V V v v v
rfl 0 in VD O
M N 77 V o0 N ,_,
C N O O v
Daily Total Residual Chlorine
(IaPI}e
C
EiO
W
Average IMinimumIMaximum
g
O
0
O
l—
N
o 0
oo ON
O O
CD CD
0 0
V1 O
M M
M N
0
(-
O
CD
0
00
VD
0 0
VC (V- °0
O O O O
CDO CD CD
O O 0 O
00 O vn V
(— O Vl l—
O (Ni �--i N
o 0 0 0
oo vi
O O O O
CD CD CD CD
O O O O
O\ 00 V \O
-1 (, 00 -1
O .� —+
Daily Fecal Coliform
(# / 100)
Effluent
Average MinimumlMaximum
0
O
M
V
0
0")
oil
0 g
O
M
v v
0 0
N N
00 6
0
O
4
v
0
O
00
0
O
ten
v
0
N.
4
0
O
v
0
M
t!1
0
O.
M
v
0
l-
M
0
O
M
v
0
N
4
0
O
M
v
C.
(—
(Ni
0
O
M
v
0
--,
4
0
O.
M
v
0
V1
V•1
0
O
N
v
0
r-
M
VD VD VD
O O
tiw
VD
O
.
VD VD VD VD VD `O VD VD
O O O O O O O O
�""¢(nOZA
N
V
00
11
O
ti
11
v
40
CD
00
00
0
N
U
Permit Limits
N
00
00
N
(NC00203 89)
"C7
1
04
Water Permit

Total Chromium
(ug/L)
Effluent
0
vi
V. V V V V V V V V V V
Daily pH
Effluent
IMinimuml Maximum
M
O
in
VC
a, M
00 00
N O
V't N
M
O
,D
O
r-+
00
U1
O
N
V1
N
O
-0
O
N
O N
-1N
,D N
O
-,
O
M
0
Lt 1
.-,
(-
d-
Total Zinc (ug/L)
Effluent
5
C=�
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ci
E
E
cc
Q
V'1 kr c!1
(- vD 00
M,
(� •l!1
\D
M - (r V1 VN'1
N t-M M V'1 M �D —
M M M. kn M krk
M •-- Vl k• s d- •---
Total Copper (ug/L)
Effluent
Average Minimum Maximum
00 O
0
V V— V
0 0 0 0 0
V V V V V
O_ O_ O_O
V V' V N
O
V
0
V
O_
V
O O O O
00 0
V-- V V V
0 0 0 0 0
V --'V V V V
O_ M O_ O_ O_
V' V V V
Conductivity
Effluent
Average !Minimum I Maximum
,D
rn
M
a,
N
N
(-
M
00 ,D
a, o
M ,r
a, V
N M
N
(- 00
M M
00
a,
M
v1
M
N
00
M
cr
M
,D
M
•--i
00
M
M
M
N
0
M
M
M
O
VD
M
00 ,
a,
M M
,D
M M
,--, N
00 00
M M
O
O
,r
M
Q\
\D
M
�n
0
M
N
00
N
M
00
M
M
0
wl
M
,D
O
'mo
,D
i
OfaO
O O O O O O O O O
; i i i �+ i
d `�','-,Q(A04a)
v
6
0
0
a\
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VC
O
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a,
0\
00
0
0
0
U
Water Permi
Data does not m
(c
0
0
N

Appendix 6.1— TWC Speculative Limits Request (6/25/01)

OCT-05-206\16:38 FROM:THE WOOTEN COMPANY 919 8343589
TO:9197330719 P.2/2
r
12Le VeAlk
Company
Engineering
Planning
Architecture
170 N Poy4n Avenue
Raleigh, NC
a603
Y19421-0531
Fair 919.034-3M9
Since I93f,
June 25, 2001
M. Dave Goodrich, NPDES Unit Supervisor
Division of Water Quality, NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699
Re: S eculativc NPDES Limits_ _
'Tow.n..oEBe.nson,-Johnston County
NPDES Permit No. NC0020389
Dear Mr. Goodrich:
We are currently preparing a 201 Wastewater Facilities Plan for the Town of Benson
who operates a 1.5 mgd wastewater treatment facility under NPDES permit number
NC0020389- This facility discharges to Hannah Creek, a tributary to the Neuwe River.
We are requesting that the NPDES Unit prepare and transmit speculative permit linuts
to our office should this facility be permitted to discharge 3.0 msd of wastewater to
Hannah Creek, the current permitted discharge location.
If you should halve any questions, please contact our office.
Sincerely,
THE W O'T'EN U
A
Gary artong
cc: TWC Files
ANY

Appendix 6.2 — DWQ Response to Speculative Limits Request (1/23/06)

NCDENR
Mr. Gary Hartong
120 N. Boylan Ave.
Raleigh, North Carolina 27603
2273-- 4-
Michael F. Easley
• Governor
Wi
iam G.
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
January 23, 2006
Subject: Speculative Limits Request
Town of Benson
Johnston County
Dear Mr. Hartong:
The Division evaluated your request in behalf of the Town of Benson for speculative Iimits for an increase
discharge of 3.0 MGD at the Benson WWTp. The Division cannot issue speculative limits for 3 MGD at this
time. Hannah Creek is listed in the North Carolina 303(d) list of impaired waters as impaired for dissolved
oxygen. The Division will not allow any increase in loading to the creek as long as it is listed as impaired. If the
conditions of the creek improve and it is removed from the 303(d) list, an increase in flow could be evaluated. If
you have any questions, please contact Teresa Rodriguez of the NPDES Unit at [phone], extension 553.
cc: Raleigh Regional Office, Surface Water Protection
EAST NPDES Unit Files
Town of Benson — Keith Langdon
Sincerely,
Gil Vinzani
EAST NPDES Unit Supervisor
JAN 2 4 2006
THE WOOTEN COMPANY
1617 Mail Service Center, Raleigh, North Carolina 27699.1617
An Equal Opportunity Affirmative Action Emptayer
Telephone [phone] FAX [phone]
Vise' Us ON THE rrTrtpNET (4) http://h2o.enr,state.nc,us/NPDES

Appendix 7.1 — Preliminary WWTP Expansion Calculations

Appendix 7.1
Preliminary WWTP Expansion Process Calculations
1.0 Design Influent Wastewater Characteristics
See Table 6.1 in text.
2.0 Design Effluent Limitations
See NPDES permit for 1.9 mgd discharge in Appendix 2.1.
3.0 Oxidation Ditch Design
Use all three (3) existing oxidation ditches. Raise the walls of all three (3) ditches to
increase the volume in each ditch to 1.236 MG. In normal operation, send all raw
wastewater and return sludge to the middle ditch. Brush rotors in middle ditch will be
turned off. Existing mixers in this ditch will keep mixed liquor moving. The middle
ditch will be anoxic for denitrification. The two (2) outside ditches will be run
aerobically. Add internal recycle pumps to bring total internal recycle capacity to 12
mgd to move mixed liquor from the middle ditch to the outside ditches for BOD5 removal
and nitrification and to move nitrate -laden mixed liquor from outside ditches to middle
ditch for denitrification. Mixed liquor will leave the outside ditches and flow to the
secondary clarifiers.
T = V/Q
V = 1.236 MG per upgraded ditch
Q = 3.00 mgd average
Average T = 19.8 hrs. for 2 ditches
= 29.7 hrs. for 3 ditches
Use MLSS = 3,000 mg/1.
Average F/M = ((200 mg/1 BOD5)(3.00 mgd))/((3,000 mg/1 MLSS)(1.236 MG/basin)(#
basins))
= 0.08 # BOD5 / # MLSS-d for 2 ditches
= 0.05 # BOD5 / # MLSS-d for 3 ditches
(1.236 MG/basin)(# basins) = (200 mg/1 BOD5)(0.65 # TSS / # BOD5)(3.00 mgd)(SRT in
days)/(3,000 mg/1 MLSS)
Average SRT = 19.0 d for 2 ditches
= 28.5 d for 3 ditches
1

BOD5 loading = ((200 mg/1 BOD5)(3.00 mgd)(8.34 #/MG per mg/1))/((# basins)(1.236
MG/basin))
BOD5 loading = 15.1 # BOD5 / 1,000 CF-d for 2 ditches
= 10.1 # BOD5 / 1,000 CF-d for 3 ditches
BOD5 loading = ((200 mg/1 BOD5)(3.00 mgd)(8.34 #/MG per mg/1))/(1.236 MG/basin))
= 4048.5 ppd BOD5 x SF of 1.5
= 5,004 ppd BOD5
Total 02 required (excluding denitrification credit) = (5,004 ppd BODs)(1.5 # 02 / #
BOD5) + (1,015 ppd NH3-N)(4.6 # 02 / # NI-13-N) = 12,175 ppd 02
Denitrification:
F/Mb peak = (5,004 ppd BOD5)/((1.236 MG)(3,000 mg/1 MLSS)(0.8
MLVSS/MLSS)(8.34 #/MG per mg/1)) = 0.20 # BOD5 / # MLVSS-d
SDNRpeak = (0.03)(0.20) + 0.029 = 0.04 # NO3-N / # MLVSS-d
NOr peak = (1.236 MG)(0.04 # NO3-N / # MLVSS-d)(3,000 mg/1 MLSS)(0.8
MLVSS/MLSS)(8.34 #/MG per mg/1) = 990 ppd NO3-N capacity at 20°C = 40
mg/1 removal capacity at 3.00 mgd
NOr peak at 10°C = (990 ppd)(1.026)10-20 = 776 ppd NO3-N capacity = 31 mg/1
removal capacity at 3.00 mgd
Thus, at 20°C, removal capacity = 990 ppd < peak load = 1,015 ppd.
At 10°C, removal capacity = 776 ppd = 75% of peak load = 542 ppd.
Denitrification filters are required to achieve effluent limits.
Use IR = 4Q = (4)(3.00 mgd) = 12.0 mgd. This should produce Ne = 3.3 mg/1
NO3-N on average at peak load conditions. With a TKN in effluent of 2.3 mg/1,
then Total N in effluent = 3.3 + 2.3 = 5.6 mg/1.
02 credit for BOD5 used in denitrification at 10°C = (2.86 # 02 / # NO3-N
denitrified)(766 # NO3-N denitrified) = 2,190 ppd 02
True Peak AOR = 12,175 ppd 02 - 2,190 ppd 02 = 9,985 ppd 02
Use SOR/AOR = 1.66.
SOR = (1.66 SOR/AOR)(9,985 ppd 02) = 16,575 ppd 02
2

Solution:
Abandon all existing brushes and replace with five (5) 20-hp baffled brushes in each of
the three (3) oxidation ditches, for a total of fifteen (15) new brushes.
Under worst case peak conditions, run all brushes in both outside ditches and two brushes
in middle ditch.
This will result in a supplied SOR = ((20 hp/brush)(10 brushes)(3.0 # 02/hp-hr) + (20
hp/brush)(2 brushes)(3.16 # O2/hp-hr))(24 hr/d) = 17,434 ppd 02,
Partial use of the middle ditch for aerobic conditions should not be a problem under this
extreme peak condition due to the abnormally large size of the basin for use as an anoxic,
denitrification tank.
Under average conditions, SOR = 16,575/1.5 = 11,050 ppd 02, Under this condition, run
a total of eight (8) 20 hp brushes in outside ditches.
4.0 Clarifiers
Add one (1) new, 50-foot diameter by 14-foot SWD clarifier. With the fair existing 35-
foot diameter clarifiers, and the one (1) 50-foot by 14-foot SWD clarifier to be added
during the interim improvements, this will provide a total surface area of 7,775 sf.
Use MLSS = 3,000 mg/1 and 100% RAS.
Average overflow rate = 386 gpd/sf
Peak overflow rate = 965 gpd/sf
Average solids loading rate = 0.80 # MLSS/sf-hr
Peak solids loading rate = 1.41 # MLSS/sf-hr
5.0 Filters
Existing filters are dual media with total surface area = 600 sf. These filters will be kept
as is / will be upgraded to denitrification filters. New, parallel denitrification filters with
an added surface area of approximately 600 sf will be added. Methanol addition will
accompany the new filters.
Average filter rate = 1.7 gpm/sf
Peak filter rate = 4.3 gpm/sf
Denitrification Filters:
Assume 5.25 ft of media depth
Assume 100% NO3-N removal for loading rate purposes
3

Loading Rate = (3.3 mg/1 NO3-N)(8.34 #/MG per mg/1)(1.5 mgd)/(598.50 sf)(5.25 ft)
= 13.14 ppd NO3-N / 1,000 CF
This is well within the typical treatment capacity of 62 ppd NO3-N/1000 CF for
downflow denitrification filters.
6.0 Chlorination
Maintain existing chlorination/dechlorination equipment to treat reuse water to meet its
stricter requirements and to serve as a backup to new UV disinfection.
Provide UV disinfection system to handle the average daily and peak daily flows of 3.0
and 7.5 mgd, respectively. The UV disinfection system will be designed to comply with
the NPDES fecal coliform limits.
7.0 Sludge
Rough approximation of sludge produced = (0.65 # sludge / # BOD5)(200 mg/1
BOD5)(3.00 mgd)( 8.34 #/MG per mg/1) = 3,253 -* 3,300 ppd.
Clarifier underflow concentration (at 100% RAS) to produce a MLSS = 3,000 mg/1 —
6,000 mg/1 — 0.60% solids.
3,300 dry ppd of 0.60% solids — 66,000 gpd sludge wasted.
Volume of sludge storage available = 3,260,000 gallons ±.
This is enough storage for nearly two (2) months, assuming the sludge does not
concentrate any. However, the sludge will tend to thicken in the basin over this period of
time, thus providing longer storage.
Total dry tons produced per year = (3,300)(365)/(2,000) = 602 dry tons per year.
This exceeds the town's existing residuals land application permit limit of 250 dry tons
per year. As production increases, the town will need to obtain additional land and
increase the limits of its permit.
4

Appendix 8.1 — FEMA Flood Maps

STATE OF NORTH CAROLINA FIRM PANEL LOCATOR DIAGRAM
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DATUM iNFORMATION
The projection used In the preparation of this map was the North Carolina
State Plane (FIPSZONE 3200), The horizontal datum was the North American
Datum of 1983, GRS80 ellipsoid, Differences in datum, ellipsoid, projection, or
Universal Transverse Mercator zones used In the production of FiRMs for adjacent
jurisdictions may result In slight positional differences In map features across
Jurisdictional boundaries, These differences do not affect the accuracy of this
FIRM, All coordinates on this map are in U.S, Survey Feet, where
1 U,S, Survey Foot - 1200/3937 Meters,
Flood elevations on this map are referenced to the North American Vertical
Datum of 1988 (NAVD 88). These flood elevations must be compared to structure
and ground elevations referenced to the same vortical datum. An average
offset between NAVD B8 and the National Geodetic Vertical Datum of 1929
(NGVD 29) has been computed for each North Carolina county, This offset was
then applied to the NGVD 29 flood elevations that were not revised during the
creation of this statewide format FIRM, The offsets for each county shown on
this FIRM panel are shown In the vertical datum offset table below, Where a
county boundary and a flooding source with unrevlsed NGVD 29 flood elevations
are coincident, an Individual offset has been calculated and applied during the
creation of this statewide format FIRM, See Section 6,1 of the accompanying
Flood Insurance Study report to obtain further Information an the conversion
of elevations between NAVD 88 and NGVD 29. To obtain current elevation,
description, and/or location Information for bench marks: shown on this map,
please contact the North Carolina Geodetic Survey at the address shown below.
You may also contact the Information Services Branch of the National Geodetic
Survey at [phone], or visit their website at www,ngs,noaa,gov,
North Carolina Geodetic Survey
121 West Jones Street
Raleigh, NC 27601
[phone]
www,ncgs,state,nc,us
County Average Vertical Datum Offset Table
County Vertical Datum Offset (ftj
Johnston - 0,94
Example: NAVD 88 NGVD 29 + (--0.941
All streams listed In the Flood Hazard Data Table below were studied by
detailed methods using field survey. Other flood hazard data shown on this
map may have been derived using either a coastal analysis or limited detailed
riverine analysis, More Information an the flooding sources studied by these
analyses is contained in the Flood Insurance Study report.
2 140 000 FEET
500 000 FEET
35' 23' GO
sera an m
35'22'00"
3810 00M
585 000 FEET
35' 21' 00
3914 ax"
Johnston County
Unincorporated Areas
370138
ZONE X
78* 3 I' oo" JOINS PANEL 1640
Note to User:
This lueliminary FIRM panel contains updated flood hazarr d information for
the Neise River basin only, Updated flood hazard Inform eetlon for
the Ca)e Fear River basin portion of this panel will be adddeced at a later date,
For Jlcl(d hazard information in areas outside of the Nerc,.;ssse River basin,
users r4this preliminary FIRM panel shall reference the crruirrently effective
Flco.IC.7ne_crance 5tzcdvr',1 and FIRM(s) ft>'- the n_rrrovriate area
680 000 FEET
2 140 OGO f r_
726 coo M
78°31'00" 2 145 000 FEET
78'30' 00"
726 ,°0 M 370138 ZONE X,
Johnston County
Unincorporated Areas
7e`3o' °°"JOINS P
728 OOP M
76•2e'00^ JOINS PANEL 1650
2 155 000 FEET
78'28' 00"
730 000 u
2 160 000 FEET
800 000 FSET
3020 00o
595 000 FEET
35`23'00"
—3918000N
CO
U7
w
z
a_
z
O
35" 22' 00"
3916 D0o N
35.2 1' 00"
3914 0°0 N
580 000 FEET
2 160 000 FEET
NOTES T
USERS
( t°ofierating I.cc1111ic•.tl St,itc
This digital Flood Insurance Rate Map (FIRM) was produced through a unique
cooperative partnership between the State of North Carolina and the Federal
Emergency Management Agency (FEMA), The State of North Carolina has
Implemented a long term approach of floodplain management to decrease
e' com-
mitment the State's onst d s err
s i d by Thi
withflooding,
wi
the
costs associated
e ort the
to map floodplain areas at the local level As a part of this effort,
State of North Carolina has joined In a Cooperating Technical State agreement
with FEMA to produce and maintain this digital FIRM,
www.ncfloodmaps.com
This map Is for use In adminlste'1ng the National Hood Insurance Program. It does neat
necessarily Identify all areas sullect to flooding, particularly from local drainage sourcees
of small size. The community map repository should be consulted for possible updatered
or additional flood hazard information.
To obtain more detailed Information in areas where Base Flood Elevations (BFEEEs)
and/or floodways have been determined, users are encouraged to consult the Fl000d
Profllos, Floodway Data and/or Summary of Stillwater Elevations tables contained withmin
the Flood Insurance Study (FlSlreport that accompanies this FIRM, Users should boe
aware that BFEs shown on the FIRM represent rounded whole -foot elevations. These
BFEs are intended for flood insurance rating purposes only and should not be useed
as the sole source of flood elevation information, Accordingly, flood elevation datta
presented in the FIS report should be utilized in conjunction with the FIRM for purposs
of construction and/or floodplain management,
Boundaries of the floodways
May
s were
re computed uteri at coss sections and interpolated beteeen
cross sections, The floodways were based on hydraulic considerations with regard tern
requirements of the National Food Insurance Program, Floodway widths and othe;er
pertinent floodwey data are provided in the Flood Insurance Study report for the jurisdictionras,
Certain areas not In Special Flood Hazard Areas may be protected by flood control.
structures. Refer to Section 4,4 "Flood Protection Measures" of the Flood Insurance
Study report for Information on flood control structures in the jurisdictions,
Base map information and geospatial data used to develop this FIRM were obtained from
various organizations, including the participating local community(ies), state and federal
agencies, and/or other sources, The primary base for this FIRM Is aerial imagery acquired as
part of the National Digital Orthophoto Program, The time period of collection for the
9 Information andgeospatial data supplied bythe local cornmunit (les
imagery is 1 98-1999 Info i I d)
g ryg p PP Y
that met FEMA base map specifications were considered the preferred source for
development of the base map, See geospatial metadata for the associated digital FIRM
for additional information about base map preparation,
Base map features shown on this map, such as corporate limits, are based on the
most up-to-date data available at the time of publication, Changes in the corporate
limits ma
y have occurred since this map was published, ed Mapuse
rs should
consult the appropriate community official or weosite to verify currenttnondi conditions of
f urisdictional boundaries and base map features,
This map reflects more detailed and up-to-date stream channel configurations than
those shown on the previous FIRM for this jurisdiction, The floodplains and floodways
that were transferred from the previous FIRM may have been adjusted to conform to
these new stream channel configurations, As a result, the Flood Profiles and Floodway
Data tables In the Flood Insurance Study report (which contains authoritative hydraulic
data) may reflect stream channel distances that differ from what is shown on this map,
Please refer to the separately printed Map Index for an overview map of the county
showing the iayout of map panels; commun
ity maprepository rY addresses; and a Listing of
Communities table containing National Flood insurance Program dates for each community
as well as a listing of the panels on which each Is located,
If you have questions about this map, or questions concerning the National Flood
Insurance Program in general, please call 1-877-FEMA MAP (1-877-336-2627) or visit the
FEMA website at www.fema,gov,
An accompanying Flood Insurance Study report, Let
terter of MapRevision (LOMR) orLetter
of Map Amendment (LOMA) revising portions
of thls panel,and digitalversions ofthis s
FIRM may be available, Visit the North Carolina Floodplain Mapping Program website
at www,ncfioodmaps,com, or contact the FEMA Map Service Center at 1-800--358-9616
for Information on all related products associated with this FIRM, The FEMA Map Service
Center may also be reached by Fax at 1-800-358-9620 and their website at www,fema,gov/msc,
'AAAP REPOSITORv
Refer to listing of Map Repositories on Map Index or
EFFECTIVE DATE OF FL000 INSURANCE.
EFFECTIVE DATE(S) OF REVISIONS) TO
For ,community map revision history prior to countywide rna
H1stto �tabIe located
din the Flood insu
rance ce Stu
dy repor
t
et r 'r To rid e m ne If fro ins
urance in ranee is available in this commrrni,
Norttlfo Carolina Division of Emergency Management or the Nati
folloovNing phone numbers or websites:
NC CDivision of Emergency Management
(919)) 715-8000 www.nflp,ncem,org
1-8
ping, refer to the Community Map
this jurisdiction.
, contact your insurance agent, the
nal Flood insurance Program at the
ational Flood Insurance Program
-6.384620 www,fee'a,:-ovhflp
LEGEND
MISPECIAL FLOOD HAZARD AREAS (SFHAs) SUBJECT TO
iNUN[DATION BY THE 1% ANNUAL CHANCE FLOOD
The 1% annual chance flood (100-year flood), olio known as the base flood, Is the flood
that has a 1% chance of being equaled ar exceeded In any given year. The Special
Flood Hazard Area is the area subject to flooding by the 1% annual chance flood. Areas
of Special Flood Hazard include .Zones A, AE, AH, AO, AR, A99, V, and VE. The Base
Flood Elevation is the water -surface elevation of the 1% annual chance flood,
ZONE A No Base Flood Elevations determined.
ZONE AE Base Flood Elevations determined.
ZONE AH ElFlood evations depthsdeteromf 1inetod, 3 feet (usually areas of ponding); Base Flood
Flood depths of 1 to 3 feet (usually sheet flow on sloping terrain);
average depths determined. For areas of alluvial fan flooding,, velocities
also determined.
Special Flood I lazard Area formerly protected from the 1% annual
chance flood by a flood control system that was subsequently
decertified. Zone AR indicates that the former flood control sysfr m is
being restored to provide protection from the 1% annual chance or
greater flood.
ZONE A99 Area to be protected from 1% annual chance flood by a Federal
flood protection system under construction; no Base Flood Elevations
determined.
Coastal flood zone with velocity hazard (wave action); Base Flood Elevations
determined.
ZONE AO
ZONE AR
ZONE VE
FLOODWAY AREAS iN ZONE AE
The floodway is the channel of a stream plus any adjacent floodplain areas that
kept free of encroachment so that the 1% annual chance flood can be carried
substantial Increases in flood heights.
L
ZONE X
ZONE D
OTHER FLOOD AREAS
must be
without
Areas of 0.2% annual chance flood, areas of 151, annual chance flood
with average depths of less than 1 foot or with drainage areas fess than
1 square mile; and areas protected by levees from 1 % annual chance
flood,
OTHER AREAS
Areas determined to be outside the 0.2% annual chance floodplain.
Areas in which flood hazards are undetermined, but possible,
COASTAL BARRIER RESOURCES SYSTEM (CBRS) AREAS
OTHERWISE PROTECTED AREAS (OPAs)
CBRS areas and OPAs are normally located within or adjacent to Special Flood Hazard Areas,
1% annual chance floodplain boundary
0.2% annual chance floodplaln boundary
^~ -~ -- -- Floodway boundary
Zone D Boundary
CBRS and OPA boundary
Boundary dividing Special Flood Hazard Areas of different
Base Flood Elevations, flood depths or flood velocities.
Base Flood Elevation Iine and value; elevation in feet*
Base Flood Elevation value where uniform within zone;
elevation In feet*
*Referenced to the North American Vertical Datum of 1988
-�-r-f-•�513�'-'
(EL 987)
97'07'30 32'22'30u
4276 sea H
1 477 500 FEET
BM5510 X
BM5510
0 M1,5
Cross section line
Transect line.
Geographic coordinates referenced to the North American
Datum of 1983 (NAD 83)
2000-meter Universal Transverse Mercator grid ticks, zone 17
5000--foot grid values: North Carolina State Plane coordinate
system (FIPSZONE 3200, State Plane NAD 83 feet)
North Carolina Geodetic Survey bench mark (see explanation
in the Datum Information section of this FIRM panel).
National Geodetic Survey bench mark (see explanation in
the Datum Information section of this FIRM panel).
River Mile
GRID NORTH
MAP SCALE 1" = 1000' (1 : 12,000)
500 0 1000 2000
FEET
I H H 1
300
300
METERS
c00
1
11111
11
1111
I�i
1
111�--.
lii
PANEL 1548 J
11111
11
m111
RA*
sic,..
,
FIRM
FLOOD
INSURANCE
RATE
MAP
0�i
NORTH CAROLINA
110111011"
' •
II1II1II
PANEL 1548 Wit
(SEE LOCATOR DIAGRAM OR MAP INDEX FOR FIRM
PANEL
1
1
LAYOUT)
CONTAINS:
�••." i1
COMMUNITY NUMBER PANEL SUFFIX
lighlii
�Iq ..
COJOHNSTON
BENSON, TOWN OF 370504 1548 J
COUNTY 370138 1648 J
imm
1T'
r• ...1
unnt
CID
1'CO
CID
di
Notice to User: The lisp Number shown below should be used
when placing map orders; the Community Number shown
above should bf3 used on Insurance applications forthe subject
commun ttY•
11Q
EFFECTIVE DATE MAP NUMBER
F.3720154800
CID
1
y
'r.
r
IIIIi
t"' •• •
M t G
Ili1
ti a'
,
.
1,...• 1
State of North Carolina
IIIIII I
Federal Emergency Management Agency 9