NC0020389_Pretreatment Compliance Inspection Letter and Report_20240702

DocuSlgn Envelope ID: 0OF57B8B-33AA-4F68-AD23-225562530340
ROY COOPER
Governor
ELIZABETH S. BISER
S-ra tejue V
RICHARD E. ROGERS, JR
Ulreeme
NORTH CAROLINA
Environmental Quality
July 2, 2024
Ms. Kimberly Pickett
Town Manager
Town of Benson
P.O. Box 69
Benson, NC 27504
Subject: Pretreatment Compliance Inspection
Benson Wastewater Treatment Plant
NPDES Permit No. NCO020389
Johnston County
Dear Ms. Pickett:
On June 27, 2024, Donald Smith of the Division of Water Resources (DWR) - Raleigh Regional Office
conducted a Pretreatment Compliance Inspection (PCI) of the program at the Town of Benson (Town).
The assistance given by Mr. Brian Leavitt — Superintendent -ORC was greatly appreciated. Findings
during the inspection were as follows:
1. Currently, the Town has one Significant Industrial User (SIU) — Chicopee -- Berry Global, Inc.,
2. The pretreatment files of Chicopee (0001). The files needed for review were available for
inspection, contained all the required elements and were in good condition and well organized.
The SIU was compliant during the most recent seini-annual period (July 2023 December
2023). The Town's Pretreatment Program inspected the SIU as identified in the permit.
3. A review of the files containing the pretreatment program elements (head works analysis,
industrial waste survey, enforcement response plan, short-term monitoring plan, and sewer use
ordinance) was conducted. These files were available for review and well organized. All
elements were up to date, with some awaiting DWR review and/or approval. A Head Works
Analysis (HWA) was submitted September 25, 2020, with three subsequent revisions with the
last revision on February 22, 2022. An industrial waste survey (IWS) was submitted June 20,
2024. The Town is awaiting DWR approval for the HWA and IWS.
4. Mr. Leavitt indicated that a Short -Term Monitoring Plan (STMP) was set to begin soon to
prepare for one year of monitoring data before the NPDES Permit expiration (April 30, 2026).
STMP data will be available with the NPDES permit renewal application. Please ensure that
required minimum practical quantitation limits are used for the STMP data collection. NC PQLs
can be found at https:. www.deq.nc.gov:`pgls'download?attachment
5. Fiscal Year 2023 - Pretreatment Annual Report (PAR) dated February 26, 2024, was reviewed
during the inspection. The PAR included an Allocation Table (AT) based on the last DWR
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Vonh Carolina Dcpanmcnt of Lnvironnkcntal
Quality j
on of 1Vatcr Resources
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Raleigh Regional 011ice 1
3800 Barren Drive I
Raleigh, \onh Carolina 27601)
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919.791.4200

DocuSign Envelope ID OOF57B8B-33AA-4F6B-AD23-225562530340
approved HWA from September 25, 2020. Lead, Zinc, and Copper were identified in the AT as
being overallocated. The AT also did not include Nickel. Please submit a revised 2023 PAR to
include the most recent revision of HWA and AT that has been submitted to DWR, even if
it has not been approved by DWR. The 2023 PAR also included an Industrial Data Summary
Form (IDSF) that included "NIA" for all calculated SIU permitted parameters for chronic and
technical review criteria (TRC) percent non-compliance. If a SIU is fully compliant with limited
parameters for the semi-annual compliance judgement period, the % violations and % TRC
violations would be identified by a calculated "091•0" violations. For parameters that are
monitored and not limited, "N A" or "Monitor Only" should be included for % violation
compliance judgement since compliance judgement is not being calculated. Include an updated
IDSF with your revised 2023 PAR submittal.
The Town's Pretreatment Program is satisfactory and appears to be in tune with NPDES compliance
initiatives. Thank you for your continued cooperation and support of the Pretreatment Program. If you
have any questions or comments, please call Donald Smith at [phone] or
[e-mail].
Sincerely,
EoeuSlyned by:
IU,LSSa V. ha Utt
D
297flE6AB31114F
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Enclosure: Town of Benson PCI Inspection Form
Cc: Laserfiche
North Carolina Department of Environmental Quality 1 Division orWater Resources
5I2 North Salisbury Street 1 1611 Mat] Smtcc Center I Raleigh, North Carohna 27699-1611
1719.707.90(H)

DocuSign Envelope ID: 00F57B8B-33AA-4F6B-AD23-225562530340
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION lComplete Prior To PCI; Review Proeram Info Database Sheet(s
1. Control Authority (POTW) Name: Town of Benson
2. Control Authority Representative(s): Brian avitt
3. Title(s): SuperintendenUORC
4. Last Inspection Date: 08.18;2023 Inspection Type (Check One): ❑ PCI ® Audit
S. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ® YES ❑ NO
6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES ® NO
Order Type, Number, Parameters:
ICIS CODING
Main Program Permit Number
N I C 1 0 1 0 1 2 1 0 1 3 1 $ 1 9
MMIDDIYY
1 05 101 1 21 1
Are Milestone Dates Being Met? ❑ YES ❑ NO
7. Current Number Of Significant Industrial Users (SIUs)?
8. Number of SiUs With No IUP, or With an Expired IUP?
9. Number of SIUs Not Inspected B POTW in the Last Calendar Year?
no
10. Number of SIUs Not Sampled 8 POTW in the Last Calendar Year?
11. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods?
0
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods?
0
13. Number of SIUs in SNC with Pretreatment Schedule?
0
14. Number of SIUs on Schedules?
0
15. Current Number Of Categorical Industrial Users (CIUs)?
16. Number of CIUs in SNC?
0
POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations?
If Yes, What are the Parameters and How are these Problems Being Addressed?
18. Since the Last PCI, has the POTW had any Problems Related to an Industrial
Discharge (Interference, Pass -Through, Blockage, Citizens` Complaints, Increased
Sludge Production, Etc.)?
If Yes, How are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during SNC for
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for
Public Notice?(May refer to PAR if Excessive SIUs in SNC} Not Put
20. Which Industries are on Compliance Schedules or Orders? For all SIUs on an
Order, Has a Signed Copy of the Order been sent to the Division?
21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
LTMPISTMP FILE REVIEW.-
® YES NO
Total Phosphorous
Qtr Avg Exceedance.
See comment section
on how problem was
addressed
❑ YES NO
Limits: None
Reporting: None
dished: NIA
None
YES NO
22. Is LTMPISTMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
23. Are Correct Detection Levels being used for all LTMPISTMP Monitoring? ® YES ❑ NO
24. Is LTMPISTMP Data Maintained in a Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
25. All LTMPISTMP effluent data reported on Discharge Monitoring Report? ® YES ❑ NO Division Inspector, please verify yourself'.
26. if NO to 23 - 26, list violations
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page I

DocuSign Envelope ID: 00F57B8B-33AA-4F68-AD23-225562530340
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP'STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element in
their files, complete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Pro gram Info:
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
09125�2020
Yes No
09/24/2015
N Yes Lj No
Industrial Waste Survey IWS
06(20�2024
N Yes LJ No
12/03/2018
0 Yes No
Sewer Use Ordinance SUO
0410512013
0 Yes No
04/11/2013
Yes No
Enforcement Response Plan (ERP)
02125/2020
0 Yes El No
1 03/17/2020
Yes No
Short Term Monitoring Plan (STMP)
10131/2013
N Yes Lj No
1 01/07/2014
N Yes Lj No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR I FILE REVIEW AND I IU INSPECTION)
29. User Name
1. Chicopee (001)
2. N/A
3. NIA
30. IUP Number
0001
1 NIA
NIA
31, Does File Contain Current Permit?
Yes No
Yes No
Yes No
32. Permit Expiration Date
F 12/31/2027
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or NIA
NIA
34, Does File Contain Permit Application Completed Within One Year Prior
N Yes U
Yes No
Yes No
to Permit Issue Date?
!11
35 Does File Contain an Inspection Completed Within Last Calendar Year?
Z Yes I INoI
U Yes U No
Yes Lj No
36. a_ Does the File Contain a Slug/Spill Control Plan?
a. ®Yes ❑No
a. ❑Yes ❑No
a. ❑Yes ❑No
11
b. If No, is One Needed? (See Inspection Form from POTW)
b. ❑Yes ON—
b. ❑Yes ❑No
b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
0Yes0No0Nj67;;6RZNj
OYes❑No❑NIA
Organic Management Plan TOMP)?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. ❑Yes ®No
a. ❑Yes ❑No
a. ❑Yes ❑No
b. All Issues Resolved?
b 0YesMoON A_]
b ❑Yes❑NoON A
b.❑Yes❑No❑N A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
Yes U No
U Yes Lj No
U Yes U No
its Sampling as Required by IUP, including Flow?
40. Does File Contain POTW Sampling Chain-Of-Custod Forms?
Yes NoI
U Yes U Nojj
UYes U No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Yes❑No❑N A
❑Yes❑No❑N A
❑Yes❑No❑N A
Sampling as Required b IUP, including flow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
®Yes❑No❑N A
❑Yes❑No❑N A
❑Yes❑No❑N A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoON A
❑Yes❑No❑N A
❑Yes❑No❑N A
file includeprocess/dilution flows as Required b IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N A
OYes❑No❑N A
❑Yes❑No❑N
production rates and/or flows as Required b IUP?
fl
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
Z Yes U No
U Yes Lj No
Yes No
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
ElYesONo❑N A
❑Yes❑No❑N A
❑Yes❑No❑N A
All Reporting -Non -Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.OYesMoON A
a.❑Yes❑NOON A
a.OYesONo❑N A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
b OYcs0Not1lN A
b OYesOvoON)A
b DYesMoON A
c. If applicable, Did POTW resample within 30 days of becoming aware
of SIU limit violations in the POTW's sampling of the SIU?
c.OYesONoON A
c ❑YesONo❑N.A
c.❑Yes❑No❑N A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
U Yes DQ No
Yes No
11 U Yes El No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑No®N A
❑Yes❑No❑N A
❑Yes❑NOON A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
48, Does the File Contain Penalty Assessment Notices?
❑Yes®No❑N A
❑Yes❑NO❑N.A
❑Yes❑No❑N A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑No®N A
❑Yes❑No❑N A
11 ❑Yes❑No❑N A
50. a. Does the File Contain Any Current Enforcement Orders?
a.DYesONoON A 11
a.❑YesMo❑N A
11 a.pvesONoON A
NC DWR Pretreatment Compliance Inspection (PC1) Fonn Updated December 2016 Page 2

DocuSign Envelope ID; 0OF57B8B-33AA-4F66-AD23-225562530340
b. Is SIU in Compliance with Order? _
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Inforination For You?
b OYesONo0h.A
b OYes❑No❑V A
b OY.0NoON A
Yes ED No
LJ Yes Lj No
Lj Yes Ll No
FILE REVIEW COMMENTS:
Total phosphorus quarterly average exceedance in September 2023, according to the ORC it was a result of switching chlorine
disinfection carry water from well to county water. County water contains orthophosphate as a corrosion inhibitor. Switched carry
stater back from county water to well water and have not had any additional total phosphorus non-compliance.
INDUSTRY INSPECTION 1CIS CODING:
Main Program Permit Number MMIDDIYY
I I I 1 I I I I 1 1 1 1 1 1
Industry Inspected: _ SIU inspection was not conducted during Pt'I
2. Industry Address:
3. Type of Industry/Product: _
4. Industry Contact:
Phone:
Fax:
Title:
5. Does the POTW Use the Division Model Inspection Form or Equivalent? ❑ YES ❑ NO
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly''
Comments:
A. Initial Interview
❑ YES ❑ NO
B. Plant Tour
❑ YES ❑ NO
C. Pretreatment Tour
❑ YES ❑ NO
D. Sampling Review
❑ YES [:]NO
E. Exit Interview
❑ YES ❑ NO
Industrial Inspection Comments:
OVERALL SUMMARY AND COMMENTS:
Comments: Pretreatment Program appears satisfactory and in tune with NPDES compliance initiatives
Requirements: Revise and resubmit 2023 PAR HWA and IDSF
Recommendations:
NOD: ❑ YES ® NO
NOV: ❑ YES ®NO
QNCR: ❑ YES ®NO
POTW Rating:
Satisfactory X Marginal UnSatisfactory
PCl COMPLETED BY:
OocuSigned by: DATE: 7 /2 / 202 4
St,4,, *24'FA647A
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3